Interim Compliance Officer & MLRO

• Interim Compliance Officer (SMF16) and Money Laundering Reporting Officer (SMF17)
• ROLE TITLE
• Interim Compliance Officer (SMF16) and Money Laundering Reporting Officer (SMF17)
• REPORTS TO
• Chief Investment Officer (SMF3) and Group Head of Legal & Compliance
• LOCATION
• London
• ROLE PURPOSE

To act as the FCA-approved holder of the SMF16 (Compliance Oversight) and SMF17 (Money Laundering Reporting) functions for NEC, ensuring that the Firm maintains effective systems and controls to comply with its regulatory obligations and manages financial crime risk in accordance with FCA requirements, the Money Laundering Regulations 2017, JMLSG Guidance and applicable legislation.

The role holder is responsible for providing independent second-line oversight of the Firm's regulatory compliance and financial crime framework, advising senior management on regulatory matters, monitoring compliance with applicable laws and regulations, and promoting a strong culture of integrity, conduct and compliance throughout the Firm.

KEY RESPONSIBILITIES

• SMF16 – Compliance Oversight & SMF17 Money Laundering Officer
• Regulatory Framework
• Maintain and oversee NEC's compliance framework.
• Ensure the Firm has appropriate policies, procedures and controls to comply with FCA requirements.
• Maintain an up-to-date regulatory inventory and horizon-scanning process.
• Advise senior management on regulatory developments and their impact on the Firm and potential solutions to mitigate.
• Compliance Monitoring
• Develop and maintain a risk-based Compliance Monitoring Programme.
• Monitor the effectiveness of policies, procedures and controls.
• Track, report and oversee remediation of identified compliance issues.
• Provide independent challenge to first-line business functions.
• Governance and Reporting
• Prepare regular compliance reports for the Board of NEC, relevant committees and the executive leadership team.
• Escalate material regulatory breaches and control weaknesses.
• Maintain appropriate management information and key risk indicators.
• Support governance arrangements relating to SMCR, Conduct Rules and regulatory responsibilities.
• Regulatory Engagement
• Act as principal compliance contact with the FCA.
• Coordinate regulatory submissions, notifications and correspondence working with the relevant functions across the business including Finance and HR.
• Oversee regulatory inspections, information requests and thematic reviews and proposing solutions to senior business leaders for any issues/ gaps identified.
• Conduct and Culture
• Partner with senior business leaders to promote a positive compliance culture across the Firm, setting it up as a business enabler.
• Lead compliance training and awareness programmes.
• Support implementation of programmes that meet the FCA's expectations regarding culture, governance and non-financial misconduct.
• Financial Crime Framework
• Maintain and oversee the Firm's AML/CTF and sanctions framework.
• Ensure compliance with the Money Laundering Regulations, Proceeds of Crime Act, Terrorism Act and FCA requirements.
• Maintain the Firm's Financial Crime Risk Assessment.
• Suspicious Activity Reporting
• Customer Due Diligence and KYC
• Oversee KYC and due diligence arrangements across the Firm.
• Ensure appropriate verification of customers, investors, counterparties, acquisition targets and relevant beneficial owners where required.
• Provide oversight of outsourced AML and KYC providers.
• Monitor enhanced due diligence requirements and high-risk relationships.
• AML Monitoring and Assurance
• Conduct periodic reviews of AML controls and procedures.
• Review breaches, incidents and financial crime trends.
• Ensure timely remediation of identified weaknesses.
• Report regularly to senior management and the Board on financial crime risks and mitigation activities.
• Training and Awareness
• Ensure staff receive all appropriate compliance-related training including the annual COCON and SMCR refreshers, AML and financial crime training.
• Monitor attendance of training and report in a timely manner to Board/HR (for annual certification purposes)
• Promote awareness of reporting obligations and tipping-off offences.
• Maintain evidence of training completion and effectiveness.
• Senior Manager Responsibilities

The role holder will

• Maintain the Statement of Responsibilities for all relevant roles approved by the FCA.
• Be accountable for the prescribed and allocated responsibilities assigned under SMCR.
• Ensure reasonable steps are taken to discharge their responsibilities effectively.
• Maintain adequate records demonstrating compliance with the Senior Manager Conduct Rules.
• Cooperate fully with regulators and internal governance bodies.

SKILLS & EXPERIENCE

Essential

• Experience in FCA-regulated asset management, investment management or fund management businesses.
• Strong understanding of AML/CTF legislation.
• Strong understanding of FCA Handbook requirements.

Desirable

• Experience within private funds, infrastructure, renewable energy or asset management sectors.
• Compliance or risk qualification.
• Experience implementing compliance technology and governance frameworks.
• Personal Attributes
• High integrity and sound judgement.
• Independent and willing to challenge constructively.
• Strong stakeholder management skills.
• Excellent written and verbal communication skills.
• Pragmatic and risk-aware approach.
• Ability to operate effectively with senior executives, Boards and regulators.
• KEY SUCCESS MEASURES
• Effective operation of NEC's compliance and financial crime framework.
• Timely identification and remediation of regulatory risks.
• High-quality Board and committee reporting.
• Successful management of FCA interactions and regulatory submissions.
• Completion of risk-based compliance monitoring activities.
• Delivery of AML and compliance training programmes.
• Demonstrable compliance with SMCR "reasonable steps" expectations.
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