Job Specification
Senior Manager: Onboarding & Compliance Support
Location: Guernsey
Employment: Full-time
Reports to: Associate Director, Operations
1. Role Purpose
The Senior Manager: Onboarding & Compliance Support is responsible for the effective operation, control and continuous improvement of the organisation's client onboarding, CDD/KYC, screening and associated compliance-support activities.
The role owns the operational framework through which new and existing clients and related parties are onboarded, reviewed and maintained, ensuring that requirements are completed accurately and efficiently and that matters requiring regulatory judgement or escalation are referred to the appropriate senior management officials.
The role combines technical financial-crime knowledge with operational ownership, with particular responsibility for ensuring that processes are measurable, appropriately controlled and capable of standing up to management, Board, auditor and regulatory scrutiny.
2. Key Responsibilities
A. Client Onboarding
- Lead, conduct and manage the end-to-end onboarding process for new clients, funds, entities and associated parties.
- Establish clear onboarding requirements according to the nature and circumstances of the client or relationship.
- Coordinate the collection, assessment and completion of required CDD/KYC documentation.
- Ensure beneficial ownership, controlling-person and connected-party information is appropriately captured.
- Monitor the onboarding pipeline and proactively resolve outstanding matters and bottlenecks.
- Ensure that onboarding cases are progressed within appropriate service standards.
- Identify matters requiring enhanced review or escalation and refer these appropriately.
- Coordinate effectively with Client Solutions, Operations, Fund Administration, Compliance and other relevant functions.
- Maintain appropriate records and evidence supporting the onboarding process.
B. CDD/KYC & Ongoing Reviews
- Own the operational delivery of the firm's CDD/KYC processes.
- Oversee the completeness and quality of client and associated-party records.
- Coordinate periodic and trigger-event reviews.
- Monitor upcoming, outstanding and overdue CDD reviews.
- Ensure expired, deficient or incomplete CDD is identified and appropriately remediated.
- Ensure material changes identified through ongoing review are appropriately considered and escalated.
- Maintain effective trackers, controls and management information over the CDD population.
- Support the consistent application of the firm's risk-based approach.
C. Screening & Financial Crime Support
- Oversee the operational screening programme covering sanctions, politically exposed persons and adverse media.
- Ensure potential screening matches are investigated and appropriately documented.
- Ensure clear rationales and supporting evidence are retained where potential matches are discounted.
- Escalate material, uncertain or higher-risk results to the MLRO/MLCO or other appropriate responsible officer.
- Support ongoing improvements to screening tools, processes and methodologies.
- Ensure screening activity is properly evidenced and auditable.
D. Compliance Support
- Provide structured operational support to the Compliance Officer, MLCO and MLRO and outsourced compliance team.
- Coordinate evidence and supporting documentation required for compliance-monitoring activities.
- Maintain trackers for findings, recommendations and remediation actions.
- Monitor agreed actions through to closure and escalate overdue matters.
- Support regulatory reporting and information-gathering exercises.
- Assist with internal and external audit, regulatory visits and due-diligence exercises.
- Support maintenance of the firm's compliance records and documentation.
- Assist with the preparation of management and Board reporting relating to onboarding, CDD and compliance-support activities.
E. Policies, Procedures & Controls
- Maintain documented procedures covering onboarding, CDD/KYC, screening and relevant compliance-support activities.
- Ensure procedures accurately reflect the way activities are performed in practice.
- Translate regulatory and policy requirements into practical operational processes and controls.
- Identify weaknesses, duplication and unnecessary complexity within processes.
- Coordinate remediation where control weaknesses or deficiencies are identified.
- Ensure changes to processes are appropriately documented and embedded into BAU operations.
F. Process Improvement, Systems & Automation
- Identify opportunities to streamline and automate onboarding and compliance processes.
- Work with the Business Analysis, Process Optimisation and technology functions to translate operational requirements into effective workflows and systems.
- Promote straight-through processing and structured workflows where appropriate.
- Reduce manual duplication and fragmented record keeping.
- Ensure technology-enabled processes retain appropriate human oversight, escalation, evidence and audit trails.
- Support the design and implementation of MI and dashboards that provide meaningful visibility over the function.
3. Management & Leadership Responsibilities
The role is expected to:
- Provide day-to-day expertise and direction to colleagues undertaking onboarding and compliance-support activities.
- Establish clear responsibilities, priorities and quality standards.
- Allocate and monitor work appropriately.
- Ensure outstanding matters are actively managed rather than simply recorded.
- Provide guidance on complex or unusual onboarding and CDD matters.
- Develop the technical and operational capabilities of the team.
- Promote accountability for deadlines and deliverables.
- Identify resource or capability constraints and escalate these appropriately.
- Encourage effective collaboration between Compliance, Operations and client-facing teams.
- Foster a culture of appropriate challenge and early escalation.
4. Management Information
The role should maintain meaningful management information that allows management to understand both volume and risk, including:
- current onboarding pipeline;
- ageing of onboarding cases;
- outstanding client documentation;
- incomplete CDD;
- periodic reviews due and overdue;
- trigger-event reviews;
- screening referrals and outstanding investigations;
- outstanding compliance actions;
- remediation items;
- exceptions and breaches; and
- recurring process or control weaknesses.
The role holder should use this information to identify trends, bottlenecks and areas requiring management intervention, rather than treating MI purely as a reporting exercise.
5. Key Working Relationships
The role will work closely with:
- Directors;
- Compliance Officer, MLCO and MLRO and outsourced compliance teams;
- Client Solutions;
- Operations;
- Fund Administration;
- Investment Oversight;
- Finance;
- Process Optimisation / Business Analysis; and
- relevant group and outsourced service-provider teams.
6. Experience & Technical Competencies
The role holder should demonstrate:
- Strong experience within regulated financial services.
- Good practical understanding of client onboarding, CDD/KYC and financial-crime controls.
- Knowledge of Guernsey specific AML/CFT/CPF, sanctions, PEP and adverse-media considerations.
- Experience operating within a regulated control environment.
- Ability to interpret regulatory requirements and convert them into workable processes and controls.
- Experience supporting compliance monitoring and remediation.
- Strong analytical and problem-solving capability.
- Experience producing meaningful management and governance information.
- Strong process-management and organisational capability.
- Confidence challenging incomplete or inadequate information.
- Ability to manage competing priorities and drive matters through to resolution.
- Strong written communication and documentation skills.
- Strong systems aptitude and an interest in process optimisation and automation.
7. Behavioural Expectations
The role holder is expected to:
- demonstrate ownership rather than simply administration;
- exercise sound judgement and know when to escalate;
- maintain high standards of accuracy and record keeping;
- challenge constructively where requirements have not been met;
- balance commercial responsiveness with regulatory responsibility;
- communicate clearly and pragmatically;
- work collaboratively across functional boundaries;
- identify problems early and drive them to resolution;
- continuously seek simpler and more effective ways of working; and
- demonstrate integrity, professionalism and appropriate confidentiality.
8. Measures of Success
Success in the role should be evidenced through:
- Onboarding progression: cases move efficiently through the process with clear ownership of outstanding requirements.
- CDD quality: client records are complete, appropriately evidenced and capable of review.
- Review discipline: periodic and trigger-event reviews are actively monitored and progressed.
- Screening quality: screening decisions and escalations are appropriately evidenced.
- Compliance actions: agreed remediation and compliance-support actions are actively followed through.
- Visibility: management has reliable MI showing workload, ageing, risks and bottlenecks.
- Process improvement: recurring manual work and inefficient processes are progressively simplified or automated.
- Team capability: the function operates consistently rather than being overly dependent on individual knowledge.
- Auditability: decisions, reviews, escalations and supporting evidence can be readily reconstructed.
- Stakeholder experience: onboarding and compliance requirements are communicated clearly and practically.
9. Role Boundary
A particularly important distinction for this position is that it is accountable for effective operational delivery of the function but does not replace the statutory or regulatory responsibilities of the appointed Compliance Officer, MLCO or MLRO.
Where a matter requires formal compliance judgement, regulatory notification, suspicious-activity consideration or another decision reserved for an appointed officer, the role holder should ensure that the matter is promptly escalated to the appropriate individual or forum.