Head Of Financial Crime

Job Description

Answering directly through to the Head of Risk & Compliance, the Head of Financial Crime’s primary responsibility is to support and protect the business against Fraud and Money Laundering Risk, Internal Fraud, Security and related reputational risk.

Financial Crime Monitoring and Surveillance

• Receiving and acting upon Suspicious Activity Reports, ensuring that suspicions are reviewed thoroughly and promptly, and externalised where appropriate
• Reviewing the output of IQ-EQs Compliance Monitoring Programme and working with the MLCO to enhance the IQ-EQ AML and CFT Policies, Procedures and Controls.
• Sanctions monitoring / auditing / investigation
• Dealing with financial crime the GFSC, FIS and third-party agency enquiries/communications/correspondence
• Maintaining ML / FT registers to include:
  • SAR register
  • ML enquiries register
  • Sanctions register
  • Client Payment Request Form register
  • FIS Liaison/Request for Information register

Board Reporting

• Preparation of quarterly/periodic Board reports
• Identifying areas of risk and in doing so preparing detailed succinct reports for consideration and report to the Board.
• Identifying and investing matters that that require reporting within the High-Risk Client Review Committee (HRCRC) reports.
• Consideration, generally, on an ongoing basis thematic matters emanating from the GFSC and FIS.

Policies, Procedures and Controls (PPCs)

Ensuring that where required that regulatory developments both from the GFSC, FIS and Group, are considered and incorporated within the business’ PPCs to include announcements to the business.

Financial Crime / Compliance Advisory

• Responding to internal queries, for example, those relating to the Handbook for Countering Money Laundering and Financing of Terrorism (the Handbook), Sanctions or Group Compliance PPCs etc;
• To track and manage regulatory changes/new regulatory requirements and working with the MLCO to update PPCs as required;
• Lead project teams to manage new regulatory changes or new business activities, as may be required from time to time;
• Working with the MLCO to draft AML/CFT policies and procedures, as may be required.

Annual Returns / Thematic Reviews / FIS and GFSC enquiries

A key part of the role is attendance to:

• Financial Crime Risk Returns;
• GFSC industry thematic reviews;
• FIS guidance to industry initiatives ensuring a timely response when required;
• Assisting for example in the timely response to GFSC Section 23, FIS Reg 2, 2A, Production Orders, Fraud Notices etc, as required; and
• Handling requests and queries from regulators/auditors.

Central Compliance

• Handling requests and queries from regulators/auditors/third party auditors;
• Ensuring that all financial crime related correspondences/records and registers are duly tracked and maintained and provide face to face training to all parts of the business, primarily first line of defence but ownership of the training requirements related to the financial crime in the firm overall.
• Provide advice mentoring and help train and manage junior members of the compliance team.
• Conducting AML/CFT induction training for all new staff and other basic trainings as required by the business;
• Updating AML/CFT periodic and induction training material where required;
• Engaging with and organising the delivery of periodic AML/CFT training;
• Ensuring that staff complete all mandatory Compliance training and declarations;
• Initiate and deliver / liaise with Group Learning and Support to ensure additional training is provided as required, for example; Fraud, Cyber, ABC, etc;
• Assisting with general Compliance reporting to local and Group management;
• Management of the business to comply with its obligations under the applicable laws, rules, regulations etc;
• Providing MLRO approval for transactions where required;
• Attending the Business Acceptance Committee in an advisory capacity where requested;
• Work with the MLCO to consider on a regular basis, at least annually, assess the adequacy and effectiveness of the measures, policies and procedures, as well as the actions taken to remedy any deficiencies in the business’ compliance with its obligations; and
• Establish a rolling audit/review of the risks of the business to include the examination of entities, preparing reports of the findings for quarterly Board meetings and other internal forums as required.

Team management

• Day to day management of the Financial Crime Team, including task allocation, supervision and mentoring as required;
• To act as the line manager (2-3 direct reports), carrying out Everyday Conversations, supporting professional development, approving absence requests, and acting in accordance with the policies set out in the IQ-EQ Staff Handbook;
• To propose changes to the structure and responsibilities of the Financial Crime team where appropriate in order to ensure that it is able to fulfil its duties effectively.

Key behaviours we expect to see

In addition to demonstrating our Group Values (Authentic, Bold, and Collaborative), the role holder will be expected to demonstrate the following:

• Pro-active and able to use own initiative
• Strong persuasive skills
• Excellent communicator
• Ability to instil trust