Compliance Manager - EU
Compliance Manager - EU Role Description
This role has been created in order to:
Summary of Focus
- Protect and maintain FNZ's reputation with clients and regulatory bodies across the EU
- Manage an EU team to successfully deliver Risk and Compliance Services across FNZ (EU)
- Provide clear strategic direction to the department with clearly defined deliverables
- Ensure all our EU customers are treated fairly
Role Responsibilities: Provision of core services to FNZ (EU) including:
- Compliance framework that ensures end-to-end compliance with regulation across FNZ (EU)
- Robust Compliance framework to limit material breaches across FNZ (EU)
- Clear MI delivered on a timely basis, which sets out all key Risks to the business, and supports a 'no surprises' culture
- Compliance Monitoring
- Identification of CBI and European Union (EU) regulatory change
- Compliance consultancy to the business
- Promotion of a compliant culture through education
PCF 15 Compliance Oversight & MLRO (Central Bank of Ireland (CBI))
- To prepare reports and liaise with clients on Compliance matters
- To attend clients' senior risk committees
- To liaise with auditors and consultants on Compliance matters
- Policy Owner of Regulatory Compliance supporting policies and procedures
- Develop and maintain effective relationships with the CBI and other relevant Irish/EU regulators
- Provide the senior point of contact with the Regulators that FNZ (EU) are registered with and maintain awareness of all communications with those regulators
- Ensure there are appropriate regulatory controls in place within FNZ (EU) to establish and maintain FNZ (EU)'s compliance with regulatory requirements including Conduct obligations
- Ensure that an annual risk based Compliance Monitoring Plan is carried out for FNZ (EU)
- Report to FNZ (EU) Board on compliance with FNZ (EU)'S regulatory requirements
- Ensure regulatory reporting to regulatory authorities on behalf of FNZ (EU) is timely and accurate
- Ensure compliance training is provided to EU employees
- Maintain knowledge of and competence in the regulatory environment in which FNZ (EU) operates and in the financial services industry of which it forms part
- Ensure awareness and compliance with regulatory requirements
- Be aware of and continue to comply with the CBI's Fit and Proper requirements
- Have sufficient oversight of the systems and controls in place within FNZ (EU) to ensure that it remains compliant with the CBI's rules
- Ensure that the employees in the role's areas of responsibility are competent to carry out their roles and there is adequate training in place to reach and maintain that competence
- Ensure that conflicts of interest have been identified and where possible mitigated and ensure that there is a regular review of conflicts of interest
Financial Crime Second Line Oversight
- Act as the Money Laundering Reporting Officer
- Reporting to the FNZ (EU) Board in relation to FNZ EU's adherence to the Irish Money Laundering Regulations and EU Anti-Money Laundering Directive V.
- Overseeing / carrying out / producing / reviewing (as applicable) the following:
- Annual review of the Anti-Money Laundering Policy and supporting procedures and templates to ensure it remains compliant with current applicable Money Laundering Regulations
- Review and sign off anti-money laundering / PEP and Sanctions checks on FNZ EU's clients and, where applicable, other FNZ companies carrying out contractual activities in the EU
- Annual risk assessment of EU's money laundering risk
- An annual MLRO report and ensure it goes to the FNZ EU Board
- Adequate money laundering and PEP and Sanction training carried out within FNZ EU including an annual review of FNZ produced training materials
- Horizon monitoring for any regulatory changes connected with applicable money laundering regulations and ensuring those changes are incorporated into the policy, supporting procedures, templates and training materials
- Investigation into any reports of suspicious transactions made to the MLRO and ensuring any necessary reports in connection with FNZ EU's own AML obligations are made to the relevant agencies
- AML, PEP and Sanction consultancy to FNZ EU employees
Data Protection Officer
- Ensure that Policies and procedures are in place to assist in the prevention of Financial Crime
- Ensure Financial Crime training is provided to employees on the Financial Crime policies
- Provide second line of defence monitoring of Financial Crime controls
- Ensure that there is a Data Privacy Compliance Oversight Framework in place which supports the requirements of GDPR in relation to the role and responsibilities of the DPO.
- Through the Data Privacy policies and Compliance Monitoring reviews, assign business responsibilities for actions to maintain data privacy compliance
- Maintain a risk based- approach to the oversight of data privacy compliance, taking account of the nature, scope, context and purposes of processing of personal data.
- Oversee the completion and maintenance by FNZ EU of Records of Processing, records of personal Data Breaches, records of Data Subject Rights Requests and Data Privacy Impact Assessments
- Review personal data breaches, assessing reportability of controller breaches by FNZ EU, advising on actions to be taken and assisting in identifying trends.
- Provide and update learning material for the FNZ EU mandatory e-learning module on data privacy for employees and focused data privacy training as appropriate.
- Provide data privacy awareness and guidance materials for relevant FNZ EU staff involved with personal data
- Be available to business owners and employees (data subjects) on matters relating to data privacy and data subject rights.
- Work with external auditors as required.
- Meet with clients and prospective clients in relation to data privacy compliance.
- Work with the Risk function to ensure data privacy risk is adequately captured within the Global Risk & Control Framework.
- Act as contact point for FNZ EU with the Irish Data Protection Commission including in relation to the reporting of personal data breaches by FNZ as a data controller and any prior consultation required in relation to high-risk processing of personal data
- Provide Management Information on data privacy compliance for reporting to the FNZ EU Board and governance committees
- In-depth knowledge of the EU financial services and regulatory framework
- 5-10 years' experience working at a senior level within a regulated environment
- Previous experience as a Compliance Officer
- Experience in people management
- Ability to communicate effectively at a variety of levels within a regulated environment, both internally and externally, written and verbally
- Good inter-personal skills necessary to constructively challenge senior management where appropriate
- Good attention to detail
- Experience in risk management and control