Chief Risk, Compliance & Financial Crime

REPORTS TO: Managing Director

LOCATION: Hybrid (Based from regional office Taunton or Leeds, UK)

DEPARTMENT: Risk & Compliance

FCA Senior Management Function: Yes – SMF16 and SMF17 senior management function for Liberate Wealth Limited

FCA Certification Role: No

Level of Authorisation held: Yes - B signatory

Firm Signatory?: Yes (on complaints etc. Not authorised to enter the firm into binding contracts)

Level of Responsibility: Yes

Staff Responsibility: Yes (there are no current staff reporting in to the HOC)

MAIN PURPOSE OF THE ROLE:

Reporting to the MD, with an independent reporting line into the independent non-executive director Chair of the Liberate Wealth Group for escalation purposes. The Head of Compliance, Risk & MLRO will ensure that Liberate Wealth Limited, and its branches and subsidiaries have robust risk governance, policies, procedures and processes in place to ensure that risks are identified, assessed, mitigated, monitored and reported in line with the Board approved risk appetite, resulting in a clear Risk and Compliance strategy which is well communicated across the firm. This includes ensuring that the firm has strong cultural alignment with effective risk management and compliance and that appropriate processes to support this are in place throughout the firm.

DUTIES AND RESPONSIBILITIES:

• Responsibility for leading and managing the Risk, Compliance and Financial Crime functions within the firm including the COB plan, Systems and Controls, Monitoring plan and all other regulatory procedures.
• Responsibility for developing and delivering risk and compliance strategies that are aligned to the firm’s strategy.
• Responsibility for developing a coherent understanding of risk and regulations across the business, which includes managing processes to identify and assess risk.
• Responsibility for sponsoring appropriate risk management and compliance policies for the Risk & Compliance teams and ensuring that they are effectively communicated and adhered to across the business.
• Responsibility for reporting regularly to the Board (and any other oversight committees), with appropriate timely and high-quality information regarding both functions so that the Board can discharge its responsibilities effectively.
• Responsibility for the 2nd Line of defence for all financial, non-financial (e.g., operational, cyber, conduct etc.) and investment risks.
• Representing the Risk & Compliance function on internal committees.
• Ensuring the delivery of prompt communication of key developments in the risk and compliance environment to the relevant parties, together with suggested plans and actions in a proactive manner.
• Ensuring that prospective regulatory changes are assessed and their impact on the business is communicated and implemented effectively.
• Liaising with Internal and External Auditors on risk and regulatory matters.
• Undertaking compliance and risk due diligence in support of any M&A activity the firm undertakes and reporting back any recommendations or issues identified.

Risk Management Framework

• Responsibility for reviewing and maintaining the firm’s enterprise risk management framework; including the current policies, risk registers, committees, resources employed, reporting lines and management information.
• Ensuring the firms policies and other framework documentation are relevant and in line with current regulations and industry best practice and seeking, where appropriate, Board approval.

Operational Risk

• Partnering with the COO to ensure policies, procedures and processes are in alignment with business objectives.
• Responsibility for monthly KPI reporting and developing and maintaining the Operational Risk dashboard, providing quarterly updates to the Board (and any other oversight committees).
• Responsibility for overseeing the investigation and reporting of all operational risk events ensuring all remedial actions are identified and implemented.
• Managing the existing Risk and Control Assessments process and ensuring the communication of key risks to the Board and CEO.
• Providing guidance in relation to new products/instruments; ensuring all operational risk and controls are fully considered and processes documented.
• Coordination of the Business Continuity Plan (“BCP”) program in partnership with the COO.

Market Risk

• Partnering with Financial Director to ensure policies, procedures and processes are in alignment.
• Define service required from Financial Director with regards to market risk measurement, reporting and oversight.

Investment Risk

• Oversight of the firms advisory and planned DFM/Asset Management investment risk management process to ensure mandates are managed in line with their risk profile.
• The review and monitoring of any counterparty exposures; reporting limit breaches and changes to quality or concentration risk.
• Responsibility for the preparation and distribution of risk reports covering daily VAR, tracking error and volatility reports and weekly/monthly/quarterly liquidity reports internal committees and relevant Boards.
• Maintenance of stress testing and back testing program.

Prudential

• Reviewing all FCA policy statements and requirements on stress testing and maintenance of a stress testing process that satisfies the Liberate Wealth’s Board and regulatory obligations.
• The coordination and independent challenge of prudential planning exercises including ICAAP, ICARA, Recovery Plan and Resolution Pack to comply with Board and regulatory requirements.

Compliance

• Maintaining the Compliance Framework and the Compliance department’s terms of reference in line with business model, Board established regulatory risk appetite and regulatory framework.
• Managing the relationship with the regulators, central correspondence and reporting log and regulatory visits and inspections.
• Define and maintain regulatory change management framework.
• Define and ensure delivery of compliance training and monitoring plans.
• Maintaining the Compliance manual and Compliance policies and ensuring that they are effectively communicated and adhered to across the business.
• Ensure compliance with GDPR and the Data Protection Act 2018 and that adequate data protection measures are in place.
• Providing clear, reliable and consistent advice on any compliance issues arising in the business, including in relation to any new business initiatives.
• Maintaining the firm’s Conflicts of Interest Register.
• Authorising Officer for designated financial promotions.
• Maintaining the firm’s Financial Promotions Register.
• Assisting HR with the Due Diligence and on-boarding and annual revalidation of SMCR and Certification Staff.
• Provide the Board with the annual end of year Compliance Report.

Economic crime

• Ensure policies, procedures and processes are in place and trained into the business.
• Undertake the role of MLRO for Liberate Wealth Limited (and any other group companies).
• As necessary, sponsor Economic Crime policies and procedures and oversee their implementation.
• Provide the Board with the Annual MLRO Report.

Executive Committee and other Governance Committees

• Member of the Management Committee, responsible for the delivery of the firms Balanced Scorecard for Risk and Compliance.
• Member or attendee of any other relevant firm Committees.

Other duties

• Supporting the MD, FD and Board/Executive Committee with Regulatory Affairs and Policies and procedures.
• Reviewing policies and procedures at least annually/every 18 months against FCA requirements.
• Maintaining the firm’s Policy Library.
• Performing a Risk Based Compliance Monitoring assessment at least annually and preparing a monitoring programme to ensure the risks identified are adequately controlled and managed, with clear issue resolution tracking and Board reporting is established.
• Overseeing the execution of the Compliance monitoring programme.
• Defining and overseeing the implementation of the Regulatory Change Management framework.
• Overseeing the review of marketing material to ensure that they are clear, fair and not misleading.
• Investigating and remediating regulatory breaches including notification to the regulator.
• Defining and tracking completion of mandatory training plans.
• Supporting T&C supervisors to maintain adviser certification regime and conducting annual fit & proper checks.
• Defining and maintaining the economic crime framework, policies and procedures.
• Ensuring new clients and counterparties comply with the Economic Crime Policies before an account is opened, and ensuring existing clients and counterparties continue to meet the requirements.
• Providing training to staff on anti-money laundering, sanctions, fraud, bribery and corruption.
• Preparing and presenting MLRO reports to the Board Audit & Risk Committee.
• Regulatory reporting.