Description of the Business Line or Department
The key objective of the Compliance team within SG Kleinwort Hambros is to assess the conformity of internal codes of conduct, policies or internal procedures with legal obligations and best practices applicable to its business.
Summary of the key purposes of the role
- To undertake all Money Laundering Compliance Officer duties for SG Kleinwort Hambros Trust Company (CI) Limited and affiliate companies (“Trust”) and SG Kleinwort Hambros Corporate Services Limited and the associated Fund entities and Managed entities (“CSL”)
- Assess the impact of regulatory requirements relating to AML Fincrime on relevant business area.
- Support the development and implementation of an AML Fincrime control assessment framework.
- Support the development , maintenance and implementation of effective , policies and procedures to detect and prevent money laundering, terrorist financing, proliferation financing and other financial crime.
- Develop and implement risk-based controls and procedures for monitoring and testing the effectiveness of measures to raise awareness and training designed for the detection and prevention of money laundering, terrorist financing and other financial crime.
- To assist in the facilitation, creation and continuing operation of a robust compliance and control regime within SG Kleinwort Hambros in the CI which ensures compliance with all relevant laws, regulations and internal policies and procedures.
- Evaluate the effectiveness of systems and controls of AML/CFT & other financial crime prevention systems and controls (and policies and procedures) as well as monitoring subsequent compliance with those systems and controls (and policies and procedures) being implemented through the KH Group arrangements.
- Compile and use management information to counter AML & Financial Crime.
- To work together with other Group control functions in ensuring that the SG Kleinwort Hambros CI Companies are effective in both preventing and reporting attempted Money Laundering/Terrorist Financing/Proliferation Financing and / or Fraud activity, in line with the requirements of the SG Codes.
- To work directly with other CI Compliance personnel, and colleagues in other Group offices to develop and maintain a ‘good compliance culture’ throughout the business.
- Assist with the review of and provide advice to Management and staff on specific projects as required by the Chief Compliance Officer.
Summary of responsibilities
- Support in establishing a cohesive, risk-based AML/CFT regulatory CRA & Compliance Monitoring Programme for Trust, CSL and subsidiaries and reporting on same as required.
- Ensure AML CFT Financial Crime monitoring is undertaken in detail as required.
- Ensure that regulatory and Group reporting requirements are met as required, such as the CSL and Funds Commercial & Risk Committee, Fund and Board when required.
- Escalating any identified potential weaknesses in the financial crime systems and controls within Trust and CSL
- Overseeing the completion of operational risk control assessments (GPS, COMPASS or alternates)
- Assist in the development and strengthening of relationships with the client relationship managers, operational managers, and all staff to promote best practice and ensure a good understanding of compliance requirements permeates the Group
- Oversee the AML CFT Financial Crime registers within the department across all SG Kleinwort Hambros CI businesses.
- Providing support and guidance to all Trust and CSL staff in all matters of financial crime (including sanctions, bribery & corruption, fraud, suspicious activity reporting and due diligence requirements)
- Identifying training needs, developing appropriate tools, drafting training decks and the delivery of face-to-face training as required
- Identify and promote improvements in the compliance and control culture of SG Kleinwort Hambros in the CI.
- This is a Key Person role as defined under Article 1 of the Financial Services (Jersey) Law and as such a Table 4 Qualification as defined in the JFSC TCB Guidance notes must be held.
- The Role Holder must be resident in Jersey
- Individual contributor competencies as defined in the SG Leadership Model
- Over 10 years compliance experience
- Experience in Private Banking/Wealth Management/Fiduciary
- Team Spirit & Collaboration
- Knowledge of SGKH Group operations
- Knowledge of legal regulatory and industry requirements
- Knowledge of and use of regulators’ and FIUs’ submission portals
- Knowledge of business processes, standards and industry requirements
- Communication – written and verbal to all levels of the organisation and to external third parties including regulators and law enforcement.
- Influencing –persuade and influence management and staff across SGHUK
- Project Management – participate and where necessary lead/manage
- Strategic & Commercial Awareness – develop and apply commercial awareness and business acumen in all day to day and longer term tasks