Compliance Assistant Manager / Manager - Jersey

About the role

The purpose of this role is to provide support to the Head of Compliance of Belasko Jersey Limited (BJL) specifically and more generally to the wider Belasko business.

The role will require regular interaction with staff at all levels across the Belasko Group.

Key responsibilities include:

• Support the BJL Head of Compliance and Compliance Officer, Money Laundering Compliance Officer and Money Laundering Reporting Officer (MLRO).
• Consider and respond to requests for assistance from employees in respect of compliance and AML/CFT matters.
• Keep abreast of legal and regulatory standards and changes in respect of AML/CFT/CPF in Jersey.
• Assist in preparing reports for quarterly board meetings of BJL and any operational and client companies (where applicable).
• Assisting with elements of the Compliance Monitoring Program and other ad hoc Compliance Reviews.
• Assisting with the improvement of policies and procedures that may result from Compliance Monitoring.
• Assisting with any requests for data or information from any regulatory authorities, whether routine or ad hoc.
• Supporting the Belasko Compliance Group with other ad hoc projects as and when required.
• It is envisaged that the candidate will be receptive to assuming a Key Person role within the business, either for BJL as the main Belasko Jersey license holding entity, or potentially on a number of client entities.

Qualifications & Experience:

• You will hold, or be studying towards, a relevant compliance-related qualification.
• You will have experience working within a compliance function.

Skills Required:

• Integrity, honesty and professionalism.
• Good interpersonal and communication skills.
• An appreciation of AML, Sanctions, conduct and business risk and an ability to quantify and explain this risk to other staff.
• Proactive and solution-focused.
• Deliver work of a high standard with attention to detail.
• Ability to achieve compliance goals and deadlines where operational considerations may compete.
• Prioritising own work and contributing to prioritising goals and objectives in the Belasko Group.

Head of Compliance

We are an independent fiduciary services company which is our strength as our very success depends on maintaining our reputation for providing a high level of personalised and efficient service in a small but highly competitive and knowledgeable market.

Our clients are wealthy individuals, families and institutions who need more than a fiduciary. In addition to providing fiduciary and family office services, we have an extensive network of advisers on tax, estate planning and investments.

Similarly, we offer guidance on choosing related service providers such as bankers, property managers and insurers.

Our team has a wide experience of dealing with wealth and estate planning for private individuals and complex structures for both individuals and institutions across the world.

PRINCIPAL ACCOUNTABILITIES

Head of Compliance and Risk Team and (as required) DMLRO, DMLCO:

• Support, direct and supervise the Board appointed MLRO.
• Support, direct and supervise the Board appointed MLCO.
• As Deputy MLRO, where necessary, to undertake the functions of the Money Laundering Reporting Officer for AGL and ensure there is timely evaluation and, if necessary, reporting with accurate record keeping in accordance with procedures established in the relevant PPCs as amended from time to time.
• To monitor the external AML/CTF/CPF environment including typologies and to identify the implications for Guernsey regulated businesses including policies, procedures, systems and controls and to notify or arrange training for staff as considered appropriate. MLCO / Compliance Officer (Supervised roles, subject of GFSC no objection):
• To support and advise the Board and staff in the development and implementation of PPCs to protect AGL from regulatory risks, and AML/CTF/CPF risks and to meet legal requirements and standards generally (including AML/CTF/CPF training).
• To undertake the supervised role of Compliance Officer for AGL and to ensure compliance with the legislation and regulatory codes governing the conduct of regulated fiduciary business in Guernsey.
• To deputise for the MLCO where necessary for AGL and discharge this statutory duty in accord with all relevant regulatory codes and guidance.
• To communicate compliance regulatory obligations for AGL as governed by the licence it holds from time to time, relevant new developments and PPCs to the Board and staff as appropriate including making appropriate revisions to procedures with supporting presentations and training.
• To develop and undertake appropriate risk-based monitoring programmes to assess compliance with laws and regulation including AML/CTF/CPF legislation, guidance notes, Codes of Practice and internal PPCs to identify any deficiencies and instigate action to remedy same.
• To foster a positive culture of compliance within AGL and within the wider Summit Group.
• To ensure the business is satisfying all relevant notification requirements and generally being open and transparent with all regulatory bodies.
• Produce and maintain an AML/CTF/CPF Business Risk Assessment to the Board and/or Risk Committee.
• Submit all relevant reporting data to the GFSC portal as and when required.
• Oversee and supervise the implementation of the approved Compliance Monitoring Programme (CMP).
• Chair the Risk Committee, produce written / verbal updates and escalations to the Board.
• Attend Board meetings to deliver the Head of Compliance reports and brief the Board accordingly.
• Attend New Business Committee meetings.

Employee Relations

• Establish and maintain productive and good relationships with all staff.
• Ensure that issues such as poor performance and/or conduct and behaviour relating to those in the Compliance & Risk team are dealt with and documented promptly in a consistent manner in accordance with established PPCs.

MAIN RESPONSIBILITIES AND DUTIES

• Supervise the MLRO in the following functions, and deputise in the absence of the MLRO: -

• • MLRO to be responsible for the day-to-day management and control of Suspicious Activity Reporting and Disclosures made to the FIU and for the maintenance of the SAR register and MLRO records relating to such reports;
  • MLRO to receive SARs from staff, acknowledge and evaluate to ensure that the information is considered and determined in a timely manner and in accordance with the Handbook;
  • To externalise (where appropriate) SARs to the FIU within required timescales or report to the Board Compliance and Risk Director with reason for non-delivery;
  • To ensure that the relationships are reviewed post-reporting and ensure all are reminded to avoid tipping off any third parties.  Follow up reviews of cases to close and archive;
  • To develop and maintain effective controls, including PPCs and any relevant schedules or registers, in respect of reporting including guidance on the laws and typologies / trends;
  • Board reporting

• Supervise the MLCO in the following functions, and deputise in the absence of the MLCO: -

• • To undertake regular reviews (including testing) of the effectiveness of PPCs to counter money laundering and the financing of terrorism and of compliance therewith.
  • To assist the Board to ensure that all business which AGL operates is conducted in strict compliance with all money laundering laws orders, and regulations in force and AGL’s own policies and procedures in this area, reporting any deficiencies and recommending changes.
  • To act as liaison point and respond promptly to requests for information made by the GFSC, FIU and Chief Minister’s Department.
  • To report periodically, as appropriate to the Board on compliance with the business systems and controls.
  • To keep abreast of all new legal & regulatory developments in respect of anti-money laundering and terrorist financing, and sanctions matters, and report matters of significance to the Board.
  • To ensure that recommendations are provided, where required, to the Board in relation to the enhancement of AGL’s AML/CTF/CPF policies, procedures, systems and controls. Compliance Officer.
  • To implement and supervise a Board approved risk-based CMP to ensure compliance with all laws, Codes, orders and regulations in force and AGL’s own policies and procedures and produce appropriate reports to the Board.
  • To review and/or have oversight of new business to ensure CDD is in compliance with AML legislation and AGL policies.

• To oversee and maintain statutory & regulatory registers for presentation to the Risk Committee and/or relevant Board meetings.
• To develop and maintain effective systems and controls, including PPCs and any relevant schedules or registers, for countering money laundering and the financing of terrorism, and mitigate any sanctions risks which may arise.
• To keep abreast of all new legal & regulatory developments (particularly in respect of anti-money laundering and terrorist financing) and report matters of relevance to the Board and suggest, where necessary, changes to AGL’s PPCs.
• To provide reports to the Board and any committee meetings as required.
• To assist in the preparation for any regulatory visit and to attend, as appropriate, any such visit.
• To attend in-house meetings from time to time, including for training, as may be required.
• To provide training to other staff members on regulatory and compliance issues as and when required. To ensure that staff are aware of their personal obligations and the internal PPCs. To maintain training records for AML.
• To be responsible for reviewing the completed Annual Declarations from all staff and reporting any issues annually on the Board Report.
• To be responsible and oversee AGL’s training plan and provide a general training update annually on the Board Report. To maintain AML/CTF/CPF training records.
• To be proactive in assisting with streamlining and improving the running of the office by suggesting improvements for the Board’s consideration for efficiency and enhancement.
• To be responsible for the timely notification to the GFSC of changes in senior personnel and other required notifications in accordance with the regulations and timescales set out.
• To provide and arrange compliance sign off on publications, advertising and other material which is made available to the public or Clients.

General duties/obligations:

• To ensure that filing and compliance records / files including archive records etc are properly maintained and satisfy legal and regulatory requirements.
• To assist the business in conducting its affairs in full compliance with the laws, orders and regulations,
• To discharge functions in a professional and courteous manner and carry out any other duties as may be required from time to time by the Board.
• To complete the annual appraisals in accordance with AGL’s PPCs.
• To undertake any other task as may be reasonably requested.
• To be available to undertake additional hours as may be reasonably requested.
• To maintain accurate records of time spent on each entity and ensure that entity records are updated daily. To monitor same for any direct reports (temporary or otherwise) and address effectively any deficiencies.

• To supervise, mentor and support other members of the Compliance & Risk team as required and provide on the job training and advice to direct reports or to other junior members of staff.
• To manage any fixed term / project workers as necessary and ensure appropriate allocation of fair workloads. To assist and re-distribute as necessary in order to meet deadlines.
• To lead by example managing direct reports and provide guidance and support to ensure the smooth running of the team with a good steady morale.
• For direct reports and with guidance from HR, deal with any issues relating to poor performance and/or behaviour and conduct promptly and sensitively in accordance with the Staff Handbook ensuring adequate file notes are maintained.
• To ensure that all scheduled staff absences such as holidays and training are adequately monitored and covered.
• With assistance from HR, conduct probation review meetings and Return to Work interviews as necessary. Handle any issues relating to poor attendance due to sickness or timekeeping ensuring adequate records and file notes are maintained.
• To conduct appraisals for direct reports (and self) in accordance with the policies and procedures and provide advice in relation to training and development issues.
• To assist with the recruitment of staff within your area of responsibility and ensure new staff are welcomed to AGL assisting with the induction process for new joiners as appropriate.

The list of duties is not exhaustive and may change from time to time according to business needs.

NECESSARY EXPERIENCE AND/OR QUALIFICATIONS & ANNUAL CPD REQUIREMENTS

This position requires a suitably experienced and qualified senior Compliance & Risk professional who possesses a thorough knowledge of the various obligations imposed upon AGL, including, but not limited to, the Bailiwick of Guernsey’s AML/CTF/CPF framework, including the Relevant Enactments (as defined in the Handbook, as amended or supplemented from time to time).

The person fulfilling this position will:

• be a ‘fit and proper person’ who can demonstrate the highest level of ethics and integrity in dealings with staff at all levels plus external contacts and stakeholders;
• hold relevant compliance qualification (e.g.: International Compliance Association) or experience;
• possess a high level of maturity and experience to demonstrate autonomous thinking and independence from colleagues, clients and the Board

Additionally:

• Excellent organisation, communication (both orally and written) and time management skills with all round good inter-personal communication and relationship skills.
• Ability to work on own initiative under pressure and meet deadlines. Accuracy and attention to detail are vital.
• Good understanding of AGL’s business and analytical skills and technical abilities necessary to undertake independent reviews / monitoring at a high professional standard.
• Problem-solving skillset, including identification of deficiencies and inefficiencies, and proposing appropriate solutions to remediate.

Minimum qualifications/education

Senior Compliance and Management Experience in a TCSP role, ideally 5+ years in a Supervised role of CO/MLCO/MLRO. Possessing relevant qualification, e.g., ICA Diploma level accreditation, which demonstrates a thorough understanding of all relevant requirements.

Annual CPD Requirements. Aquitaine requires senior staff to complete 25 hours of CPD or, if greater, such amount required to maintain professional qualifications.

Additional Information

Reports to: Chief Risk Officer

Direct Reports:

• • Compliance Officer, Company Secretary, MLCO
  • Deputy Compliance Officer & Nominated Officer
  • Compliance Manager
  • Compliance & Data Support

Signed

Role holder

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Line Manager

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