Jan 2025

COMPLIANCE MANAGER, MLRO, MLCO & COMPLIANCE OFFICER SOVEREIGN PENSION SERVICES (CI) LIMITED

JOB DESCRIPTION This management role involves a variety of compliance and regulatory policy matters as well as regulatory analysis administration tasks and responsibilities. The role holder also acts as the company’s Money Laundering Reporting Officer (MLRO), Money Laundering Compliance Officer (MLCO) and Compliance Officer (CO). RESPONSIBILITIES To manage compliance and regulatory risk in the business and to ensure a robust up to date framework is in place. To ensure that an adequate internal control framework is maintained to identify the risk of non- compliance within the regulatory environment, and to develop and maintain policies, procedures and controls, to manage and report on that risk. The role also includes managing a small, dedicated team of compliance personnel. As a member of the management team, the Compliance Manager will contribute to management discussions and developments and reports directly to the Managing Director. The post holder will undertake the roles of MLRO and MLCO and will be responsible for monitoring the company’s adherence to (and effectiveness of) its policies, procedures and internal controls to forestall, prevent and detect money laundering and terrorist financing, and reporting to the board on such monitoring. The post holder will also undertake the role of CO. DUTIES – COMPLIANCE MANAGER Duties will include:

• Reviewing new legislation, conduct of gap analysis and enhancement of existing processes and procedures to ensure that the company is compliant with the regulatory framework;

• Being a member of the risk committee, providing input to the Business Risk Assessment (BRA) and conducting regular reviews in relation to the identification and management of risks to which the company is exposed;

• Dealing with any points arising from risks and reports on a timely basis;

• Responding appropriately to alleged breaches, violations of rules, regulations, policies, procedures;

• Embedding a compliance culture, ethics and integrity within the company through close engagement with the board, managers and employees;

• Developing the existing risk management strategy to strengthen the mitigation of risk within the business;

• Responsibility for the production of compliance reviews and reports to the board;

• Maintenance of the compliance and regulatory risks registers;

• Assisting the board in respect of regulatory visits, new applications, responding to discussion and consultation papers and thematics issued by the GFSC, reporting and statistical returns, remedial work and enforcement actions;

• Reviewing marketing, advertising and promotional material;

• Conducting the internal investigation of compliance and risk related issues;

Jan 2025

• Conducting risk assessments and reports on new products and services, identifying any operational risks;

• Acting as first point of contact for whistleblowing;

• Acting as the liaison point with compliance colleagues within the Group and liaising as necessary with the Group Risk & Compliance Director;

• Overseeing FATCA, CRS and other international reporting obligations;

• Developing, initiating, maintaining, and revising all relevant policies and procedures together with those for the general operation of the Compliance Monitoring Plan (CMP) and all related activities to prevent illegal, unethical, or improper conduct and providing guidance to management and employees;

• In addition to the Directors, acting as an independent review and evaluation body to ensure that compliance issues/concerns within the company are being appropriately evaluated, investigated and resolved;

• Monitoring, and as necessary, coordinating compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends;

• Identifying potential areas of compliance vulnerability and risk;

• Developing/implementing corrective action plans for resolution of problematic issues, and providing general guidance on how to avoid or deal with similar situations in the future;

• Providing compliance reports on a regular basis, and as directed or requested by the Directors, to keep the Board and senior management informed of the operation and progress of compliance efforts;

• Ensuring proper reporting of breaches/violations or potential breaches /violations to the GFSC, or other agencies, as appropriate;

• Working with People Operations, and others as appropriate, to develop an effective compliance training and communication programme, including appropriate Compliance Induction training for new employees as well as mandatory on-going training for all employees and managers;

• Undertaking and reviewing due diligence in relation to new business, existing structures and changes to the same;

• Scrutinising, interrogating and updating compliance records in relation to client structures;

• Liaising with internal contacts regarding the production of compliance reports;

• As line manager dealing with all day to day personnel issues and providing motivational guidance, training, coaching support, and performance reviews, as required;

• Taking responsibility for own personal development, in line with agreed performance appraisal objectives;

• Acting as a role model for the values of the company and encouraging their use and adherence in order to create a culture which has benefits for employees, clients and the Group as a whole, including aspiring to the Group’s Mission, Vision, Values and Goals;

• Identifying and investigating issues or trends which may adversely affect business compliance and proposing any necessary action to promote business improvement;

• Carrying out risk assessments and file reviews for client structures;

• Maintaining, reviewing and implementing any compliance or risk remediation programmes agreed with the GFSC;

• Acting as authorised signatory;

• Any other related duties that may be required by a Director from time to time.

DUTIES – MLRO

Duties will include:

• Receiving internal disclosures of suspicion from members of staff;

Jan 2025

• Determining (in a timely manner) whether such disclosures should be externalised to the Financial Intelligence Unit (“FIU”);

• Recording decisions in respect of disclosures received internally and whether to externalise such disclosures;

• Reviewing and monitoring previous disclosures received and determining whether external disclosure is required;

• Maintaining a register of all internal and external disclosures;

• Acting as the main point of contact with the FIU;

• Monitoring notices and information circulated by FIU to the Company and acting thereon;

• Acting independently of the Board of the Company in respect of the MLRO’s responsibilities under the Disclosure (Bailiwick of Guernsey) Law, 2007 (as amended) (“Disclosure Law”) and the Terrorism and Crime (Bailiwick of Guernsey) Law, 2002 (as amended) (“Terrorism Law”);

• Supervising any deputy MLRO or Nominated Officer appointed by the Company;

• Providing training to staff on the role of the MLRO and duties placed on staff in respect of reporting suspicion of money laundering and terrorist financing;

• Maintaining up to date knowledge of changes to the Disclosure Law and the Terrorism Law and disseminating information to the Board and staff of the Company;

• Adhering to the requirements of the GFSC Handbook;

• Drafting, reviewing and revising the Company’s internal policies and procedures in respect of reporting suspicion, including making recommendations to the Board in relation to possible improvements thereto;

• Such other duties as shall be notified to the office holder from time to time by the Board.

DUTIES – MLCO

Duties will include:

• Overseeing the monitoring and testing of the Company’s AML and CFT policies, procedures, controls and systems and assessing their appropriateness and effectiveness;

• Responsibility for implementing and monitoring the Company’s compliance monitoring plan (“CMP”);

• Investigating any matters of concern or non-compliance arising from the Company’s CMP;

• Establishing appropriate controls to mitigate any risks arising from the Company’s CMP and remediating issues where necessary and appropriate, in a timely manner;

• Preparing, submitting and presenting reports to the Board on compliance matters, including the results of the testing undertaken and raising any issues that need to be brought to the attention of the Board.

DUTIES – CO

Duties will include ensuring regular contact with the Board to ensure the Board is able to satisfy itself that all requirements of the compliance laws and rules applicable to the Company are being met.

Jan 2025

PERSON SPECIFICATION

FACTOR ESSENTIAL (E) or DESIRABLE (D)

QUALIFICATIONS

• Minimum 5 GCSE qualifications (Grade C or above) including English and Maths

• 2 A Levels (Grade C or above) and/or Degree Level qualifications

• Compliance and/or AML professional qualifications

• Management qualification / training, or willingness to undertake the same

E

D

E D D

EXPERIENCE

• Minimum 5 years’ compliance experience

• Trust & Company administration experience

• Pensions administration experience

• Well-developed supervisory and management experience, backed by suitable training

• Presentations and/or training experience

E D D

E E

KNOWLEDGE

• A good working knowledge of how to operate Word, Excel and e-mail system

• Excellent knowledge of regulatory requirements, local codes and policy matters

• Good knowledge of Trust & Company Administration

• Good knowledge of Pension Administration

E

E

D D

SKILLS AND ABILITIES

• High attention to detail

• Confident decision maker

• Excellent analytical skills

• Must be able to keep client matters strictly confidential

• Ability to communicate clearly and concisely, verbally and in writing, in English.

• Strong report writing skills

• Ability to develop and follow detailed policies and procedures

• Excellent client and customer focus with ability to build effective relationships and establish trust, respect, and confidence

• Good people manager, able to deal with day to day people issues, including performance management

• Good time management

E E E E

E E

E

E

E

E

Jan 2025

PERSONAL QUALITIES

• Good social and presentation skills

• Amiable and approachable

• Multi-tasker

• Strong work ethic

• Flexible

• Desire to learn continuously and improve skills

E E D E D E

MOTIVATION

• Self-motivated and diligent

• Proactive in seeking new tasks and seeking to continually improve standards

• Strong commitment to organisation effectiveness and service delivery

• Demonstrates drive

E

E

E E

Last reviewed: January 2025

22045.1

Senior Administrator, Onboarding, Pensions Administration

Reference: 22045

Description: The duties of this role relate to the administration surrounding the

onboarding of new local, international and individual pension plans and ensuring that

Customer Due Diligence documentation continues to meet current requirements for

existing relationships.

What you would be doing

You will be supporting the administration team in the onboarding of local,

international and individual pension plans which will include but is not limited to:

• Administration around gathering documentation and client data for new plans

• Collecting client due diligence and updating internal systems

• Liaising with clients, members and professional advisors ensuring they receive a

professional service

• Assisting with the administration around business development activities

• Bank account opening

• Liaison with clients

• Client Periodic Reviews

• Supporting the Onboarding and implementation Manager with the training of

the team

Who you will be reporting to

• Manager, Onboarding and Implementation

Skills and experience required

• English and Maths at GCSE / AS / A Level is desirable or suitable equivalent

• Good working knowledge of Guernsey CDD requirements for individuals and

corporates

• Experience working in the finance sector on-boarding new clients

• Working knowledge of Microsoft Office, specifically Word and Excel

• Accuracy and Attention to Detail

• The ability to meet deadlines and work under pressure

• Work with minimum supervision on tasks assigned to them after an initial

briefing of the task is given

• Have the ability to work as part of team

• As often the first contact for a new client confidently respond to client queries

via the telephone, face to face and emails

22045.1

• How we support our colleagues

• Study support for relevant professional development

• Comprehensive benefits package, including bonus and pension

• We encourage a diverse workforce, hold the GET Disability Charter, Liberate

Rainbow mark and have office diversity champions

• Flexible working arrangements

• Paid volunteering days

• Personal Loans

• Monthly tea and talk

• Weekly yoga

• And much more!

Equal opportunities statement

BWCI is committed to eliminating unfair discrimination and encouraging diversity

amongst our workforce. The Partners and Senior Management demonstrate

commitment to equality and fairness irrespective of gender, marital status, race, ethnic

origin, colour, carer status, nationality, national origin, disability, sexual orientation,

religion or age. We oppose all forms of unlawful and unfair discrimination. If you

require assistance or reasonable adjustment in order to attend an interview then just

let our HR team know at the time of application.

How to apply

If you are interested in this role then please email your CV along with any other

relevant information to recruitment@bwcigroup.com.

HR14612.1

Job Title: Pensions Administrator Department: Pensions Administration, Jersey Reporting To: Manager, Pensions Administration, Jersey Last Date of Review: July 2021

Key Responsibilities

The duties of this role relate to the administration of local and international pension schemes and will include but are not limited to

· Maintenance of membership records · Payment of pensions and other benefits/expenses · Investment of pension scheme contributions · Calculation of member’s benefits · Bank account and unit reconciliations · Acquisition and liquidation of assets · Liaison with clients, banks, investment managers and trustees · Liaison with pension scheme members

Qualifications and Experience

· English and Maths at GCSE / AS / A Level (Grade A – B) is desirable · Working knowledge of Microsoft Office, specifically Word and Excel · There will be the opportunity to study for a professional qualification if desired · Previous experience in a pensions or relevant financial services administration role is

preferred

Person Specification

The ideal candidate would be able to

· demonstrate good numeracy skills and provide evidence of accuracy · demonstrate attention to detail in their work · organize and prioritize their workload · use and work to their own initiative as well as in a team · meet deadlines and work under pressure · work with minimum supervision on tasks assigned to them after an initial briefing of the task

is given · demonstrate excellent communication skills · confidently respond to client queries via the telephone and face to face

Equal opportunities statement BWCI is committed to eliminating discrimination and encouraging diversity amongst our workforce. The Partners and Senior Management demonstrate commitment to equality and fairness for all in our employment and do not discriminate on the grounds of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age. We oppose all forms of unlawful and unfair discrimination.

HR14612.1

Data Protection All applications made either speculatively or in response to advertised vacancies will be kept confidential.

BWCI do not undertake any automated selection process for recruitment. All information provided in the form of a CV or covering letter, be it on paper or electronically submitted, speculatively or for a specific advertised vacancy will be destroyed in keeping with the following timeframe.

Candidates not invited for interview – immediately once confirmation of the non-selection has been made.

Candidates invited for interview but not selected – 6 months after notification of non-selection has been made.

Candidates offered a position but choose not to take it up – 6 months after declining the role.

Candidates offered a position and subsequently employed – 6 years after termination of employment.

When a CV is submitted, it is passed only to the recruiting manager(s) involved in the recruitment to the specific position to which it refers. Any processing in relation to any other position will only proceed with the explicit consent of the candidate.

We may from time to time ask candidates to undertake skills testing or psychometric testing as part of a recruitment and selection process. In this case the results from those tests will only be used to inform the selection process, and will be retained in line with the time frames specified above.

It is not the policy of BWCI to screen prospective employees via social media channels, however, we may review a candidates LinkedIn profile.

If you have any questions relating to how we process applications for employment please contact hr@bwcigroup.com