Head of Compliance, Money Laundering Reporting Officer (MLRO) and Money Laundering Compliance Officer (MLCO)

Main Purpose:

The Head of Compliance is responsible for managing and supervising the activities of the compliance team acting as the principal point of contact for employees on day to day regulatory matters, providing the Management team with regular reports and acting as a principal point of contact with the Jersey Financial Services Commission. To also act as a member of the UBP Jersey Account Opening Committee.

The MLRO (Key Person) is responsible for receiving and assessing internal suspicious activity reports (iSARs) in accordance with UBPJ procedures, undertaking investigations as required and externalising SARs as and when required.

The MLCO (Key Person) is responsible for supporting the monitoring and controlling of the procedures of UBP Jersey and to ensure they are compliant with local legislation. To act as deputy to the Compliance Officer when necessary for the Jersey Management Committee (ManCo). To provide support to the Compliance Officer with tasks as required and to be able to cover all aspects of the Compliance Officer role.

Duties & Responsibilities:

As MLRO:

• Assist the ManCo in the fulfilment of their responsibilities for financial crime compliance (“FCC”)
• Ensure that a second line of defense, FCC strategy and framework is in place to include the relevant reporting process as per internal procedures;
• Receive, consider and decision any iSARs in accordance with internal reporting procedures;
• Prepare and submit the external suspicious activity reports (“eSARs”) to the Jersey Financial Investigation Unit (JFIU) where considered appropriate
• Manage relationships post disclosure to avoid tipping off;
• Maintain a record relating to all iSARs and eSARs and a register of all Deputy MLROs;
• Maintain a record of enquiries received from law enforcement authorities;

• Ensure that any training relating to sanctions, AML, CFT and CPF and any emerging trends raise the awareness of staff;

• Act as the liaison point with the Jersey Financial Services Commission (“JFSC”) and the JFIU and for any other external enquiries in relation to money laundering or financing of terrorism or proliferation;

• Provide advice to the management and staff of UBP in relation to anti financial crime and sanctions;

• Act as a liaison point with the Minister for External Relations for any sanctions issues;

• Provide support to and monitor the performance of the deputy MLRO(s);

• Provide oversight of iSARs investigated / decisioned by the deputy MLRO(s) to determine that it has been handled in line with procedures and in an appropriate and consistent manner, based on supporting information and documentation;

• Raise issues with the management as necessary

As MLCO:

• Ensure that a second line of defence anti financial crime framework is in place;
• Develop and maintain systems and controls (including policies and procedures) in line with evolving requirements;
• Monitor compliance with and test the effectiveness of legislation in Jersey relating to money laundering, the financing of terrorism and proliferation, and AML/CFT/CPF Codes of Practice issued under the Supervisory Bodies Law;
• Ensure that due diligence requirements, enhanced CDD measures and transaction monitoring are undertaken by the business as required;
• Ensure that accurate information on internal and external reporting is available for the ManCo;
• Respond promptly to any requests made by the Jersey Financial Services Commission or any other external authority;
• Maintain awareness of the obligations under legislation, Codes of Practice and regulation, tracking any changes and advising the business of the impact of those changes;
• Advise the management on anti-money laundering, terrorist and proliferation financing compliance issues that need to be brought to its attention;
• Report periodically, as appropriate, to the management on compliance with the Money Laundering Order and the Handbook and prepare updates to UBP Money Laundering Handbook;
• Responsible for timely notification of up-and-coming changes to Codes and results of themed visits;
• Oversight and review of the CMP testing and CMP Action Log;
  

Provision of support to the Compliance Officer with tasks to enable the function to be fulfilled, as required, including:

• Deputising for Compliance Officer on various client onboarding Committees
• Liaising with UBP Group Compliance in Geneva in respect of compliance and procedural matters
Ensuring that customer due diligence (“CDD”) requirements, enhanced CDD measures and transaction monitoring are undertaken by the business as required:

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Transaction Monitoring

• Monitoring of transactions identified by IMTF;
• Monitoring of transactions identified by GTExchange/Stelink, release as appropriate;
• Monitoring of incoming and outgoing payments and cheque/cash transactions on blocked accounts;
• Monitoring of PEPs and higher risk clients;
• Monitoring of the take-on process of new clients;

Compliance Advisory

• Support the business regarding questions relating to licensed business activities
• Support the business through the provision of training on certain regulatory topics.

Requirements:

• Strong background in the Banking and Investment sector;
• A relevant compliance qualification;
• Several years experience in a similar role
• Good sense of the relationships within the bank at all levels;
• Strong communications skills;
Solid compliance and anti-money laundering operational background;

Location: Jersey, Channel Islands

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