Name:
Job Title: Compliance Officer
Business Unit/Department: Channel Insurance Brokers Limited (“CIB” or “the Company”)
Location: Guernsey
Reporting to: Tony De Sousa
Compliance Officer (“CO”) Money Laundering Reporting Officer (“MLRO”)
Job Purpose: To act in the Key Person roles of CO and MLRO, as required under regulation, for CIB.
Authority: The individual will have: -
● sought and received a “No Objections” confirmation from the Guernsey
Financial Services Commission (“GFSC”) to act as a Key Person on behalf of the
Company in the capacities of CO , and
● approval from the Board of Directors of CIB.
● To be able to discharge their role effectively, the Board of Directors will ensure
that the individual: -
o has appropriate independence, in particular, from customer-facing and
business development roles;
o has a sufficient level of authority within the Company;
o has sufficient resources, including sufficient time,
o is able to raise issues directly with the Board; and
o is fully aware of both their and the Company’s obligations under all
Laws, Orders, Codes, Guidance and any related communications from
regulatory bodies or other similar organisations.
Experience
• Qualified in line with industry and GFSC requirements;
• A solid understanding of the business, the business’ products and services and the risks that
they expose the business to;
• Integrity, honesty and professionalism;
• Excellent interpersonal and communication skills with the ability to deal effectively with all
levels of staff and management within the CIB and PIB Group as well as clients and third-party
service providers (where applicable);
• Proactive, solution focused and self-sufficient;
• Deliver work of a high standard with attention to detail;
• Ability to achieve compliance goals and deadlines where operational considerations may
compete; and
• Prioritising own work and contributing to prioritising goals and objectives in the CIB.
Key Responsibilities The individual is responsible for the following generic activities: -
● Contribute to the production, review and revision of: -
o CIB’s Compliance policies, procedures and related supporting materials e.g., checklists;
o the compliance monitoring programme of the Company in relation to all Compliance
matters including but not limited to: -
▪ Industry standards and wider regulation1 in relation to guarding against Financial
Crime and understanding the degree that CIB is captured under such regulation.
o The Business Risk Assessments for CIB;
o Review and advise on the AML/CFT and Sanctions risks as they pertain to CIB;
o Formulate and deliver training to CIB personnel in respect of compliance matters;
o Keep abreast of legal and regulatory standards and changes in respect of all Laws,
Regulations, Orders, Guidance notes etc., in Guernsey;
o Prepare and deliver CO reports for quarterly Board meetings;
o Maintain all compliance related logs and trackers pursuant to notifications made and
information received;
o Highlight or escalate Compliance, AML/CFT and/or Sanctions matters of concern to the
Board of CIB; and
o Support preparations for regulatory visits.
● Develop and implement plans and objectives for the Compliance department in an effective and
innovative fashion.
● Assess and report progress in meeting the Compliance department’s objectives
Specific to the Key Person Roles the individual is responsible for: - CO: -
• Ensuring appropriate monitoring of operational performances and managing regulatory and compliance risk within CIB, which includes: -
• Monitoring that the internal policies and procedures are being consistently and effectively adhered to;
• Assessing and recommending amendments to internal systems and controls as well as policies, and procedures to facilitate compliance with the regulatory framework;
• Reviewing literature and marketing communications, ensuring they meet regulatory and internal standards;
• Where appropriate, promptly instigating action to remedy any deficiencies in the robust arrangements;
• Providing Senior Management and the Board of Directors with regular written reports in respect of the CIB’s compliance with the requirements of the regulations referenced above; and
• Acting as the principal point of contact with the JFSC on day‑to-day regulatory matters
1
o
Qualifications/ Knowledge/ Skills/ Experience Required:
• Qualified in line with industry and JFSC Requirements;
• At least 10 years’ experience in the industry;
• A solid understanding of the business, the business’ products and services and the risks that
they expose the business to.
• Integrity, honesty and professionalism;
• Excellent interpersonal and communication skills with the ability to deal effectively with all
levels of staff and management within the CIB and PIB Group as well as clients and third-party
service providers (where applicable);
• Proactive, solution focused and self-sufficient;
• Deliver work of a high standard with attention to detail;
• Ability to achieve compliance goals and deadlines where operational considerations may
compete; and
Prioritising own work and contributing to prioritising goals and objectives in the CIB
Role Dimensions: Internal Working Relationships The role will require regular interaction with:
• All staff at all levels across CIB;
• The Board of CIB;
• The Guernsey Financial Services Commission;
• The Joint Financial Crime Unit;
• Third-party service providers and advisors; and
• The wider CIB and PIB Group.
Conduct Rules and Fitness & Propriety
All PIB employees are expected to conduct themselves with integrity and professionalism, placing the customer at the centre of all we do and is central to our culture. You must adhere at all times to the GFSC’s Conduct Rules set out below.
Individual Conduct Rules:
1. You must act with integrity. 2. You must act with due skill, care and diligence. 3. You must be open and cooperative with the JFSC and other regulators. 4. You must pay due regard to the interests of customers and treat them fairly. 5. You must observe proper standards of market conduct.
Compliance with the JFSC Conduct Rules is required at all times and will be evidenced through annual performance reviews.
Fitness & Propriety You will be assessed on a regular basis in line with PIB’s requirements to ensure that you:
1. Maintain your ‘fitness’ at an appropriate level to undertake the function you perform in a sound and prudent manner at all times-this relates to your experience, knowledge, skills and professional qualifications (where appropriate)
2. Maintain your ‘propriety’ at all times-this relates to good repute, honesty, integrity and financial soundness. This includes advising the firm of any changes in circumstances and conflicts of interest that could materially affect your fitness or propriety.
3. Have undertaken or are undertaking all relevant training. Compliance of Fitness & Propriety will be evidenced through PIB’s annual checks on Fitness & Propriety (e.g. financial soundness), through annual performance reviews and through completion of your Fitness & Propriety Declaration.
Person specification:
Essential Desirable
Qualifications
Qualification in Compliance considered appropriate for the role by the GFSC.
Experience
Strong working knowledge of
performance and operations
management
Significant work experience as a
department director or similar
position
Knowledge
A good working knowledge of
Microsoft Word, Excel and
Outlook would be desirable.
Knowledge of Acturis would be
advantageous, however, training
will be provided.
Understanding and knowledge of
applicable regulation, GFSC
Principles, Rules and Guidance
relating to commercial and
private customers.
Understanding and knowledge of
general insurance and underlying
legal principles, however this will
be gained with professional
studies.
Familiarity with industry
regulations and quality standards
Skills
Solid computer skills, including
Microsoft Office and relational
databases and software
Exceptional communication and
public speaking skills
Outstanding leadership and
organisational skills
Competent collaborator and
skilled cross-functional
communicator
Leadership: You will need to make quick, and sometimes tough decisions. Your employees will look to you for conflict resolution and approval. Critical Thinking: Senior Management need to be able to solve problems as they pop up, analyse inefficiencies and refine company procedures.
Oral Communication: You will need to be able to speak clearly to employees and customers. Good speaking and writing skills are key.
Time Management Skills: You will be working with multiple employees and overseeing multiple projects.
Attitude
Positive, forward thinking and supportive
Signed by jobholder: Date:
Signed by Manager Date: