Compliance Officer - MLRO

Description of the Business Line or Department

The key objective of the Compliance team within SGKHCI is to ensure that the Registered Person complies fully with all its legal and regulatory obligations relating to Financial Services, AML/CFT and Data protection. Primary focus will be on regulatory compliance assessing the conformity of Laws, Regulations together with internal code of conduct, policies and procedures applicable to its business

Summary of the key purposes of the role

• To assist the Senior Compliance Officer and MLCO in Guernsey and Compliance colleagues within the Channel Islands in the facilitation, creation and continuing operation of a robust compliance and control regime within Kleinwort Hambros in the CI which ensures compliance with all relevant laws, regulations and internal policies and procedures.
• To assist in the general development of the regulatory regimes, assist in the formulation, co-ordination of responses with regard to all Kleinwort Hambros CI Companies
• To work together with other Group control functions in ensuring that the Kleinwort Hambros CI Companies are effective in both preventing and reporting attempted Money Laundering and / or Terrorist Financing activity, in line with the requirements of the Kleinwort Hambros and Société Générale Group policies on the Prevention of Money Laundering and Financing of Terrorism.
• To assist the Senior Compliance Officer and MLCO in Guernsey and 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 Head of CI Compliance & Financial Crime and the Senior Compliance Officer and MLCO.
• As MLRO, to undertake Money Laundering Reporting Officer duties for the Guernsey Bank and Trust businesses.
• To be a point of contact with the Financial Intelligence Service or FIU
• To work with other functions to ensure that SG Kleinwort Hambros Bank Limited, Guernsey Branch (“SGKHBLGB”) and SG Kleinwort Hambros Trust Company (CI) Limited SGKHTC(CI)L are effective in preventing and reporting attempted Money Laundering or funding of terrorism activity.
• To receive and manage Internal Suspicious Activity Reports from SGKHCI Staff and where necessary submit suspicions to the local FIU
• To Comply with the Guernsey Regulations the MLRO must:-
  • be a natural person;
  • be of at least manager level;
  • have the appropriate knowledge, skill and experience;
  • be employed by the firm or an entity within the same group as the; and
  • be resident in the Bailiwick.

Summary of responsibilities

MLRO Responsibilities

• To act as the MLRO for SGKHBLGB, KBGL, SGKHTC(CI)L and affiliates in Guernsey and make disclosures to relevant the Financial Investigation Unit; to act as deputy MLRO to Bank, CSL and Trust Company CI businesses in Jersey;
• Receiving, investigating and suspicious activity reports submitted by management or staff;
• To provide all necessary guidance and support to ensure the business in the Channel Islands complies with local AML and Compliance regulations;
• Assessing forthcoming changes in financial crime legislation as it affects SGKHCI’s business;
• Oversee the reviewing of new account files to ensure client take-on procedures are being met;

General Responsibilities

• To assist in the production of periodic reports, on a formalised basis, or as soon as made aware if considered necessary, covering all aspects of money laundering, financing of terrorism and wider Compliance/Regulatory issues.
• Providing support and guidance to all SGKH Channel Island staff in all matters of financial crime (including sanctions, bribery & corruption, fraud, suspicious activity reporting and due diligence requirements);
• Escalating any identified potential weaknesses in the financial crime systems and controls within SGKHCI;
• Producing reports for Guernsey management when required;
• Developing and strengthening relationships with the business heads, relationship managers, operations managers and staff to promote best practice and ensure a good understanding of financial crime requirements;
• Identifying training needs, developing appropriate tools, drafting training decks and the delivery of face-to-face training;
• Assist with the designing and implementing a comprehensive monitoring programmes to check that business continues to be conducted in compliance with all relevant financial crime obligations;
• Working with Legal to ensure compliance with criminal-related production orders received from relevant authorities;
• Production of regular and ad hoc reporting to the Private Banking business line in Paris (“PRIV”);
• Perform all duties in accordance with the principles outlined in the SGPBH Code of Conduct, as well as the policies and procedures relevant to your responsibilities, to ensure that you adhere to a culture that treats clients fairly and focuses on the long-term sustainability of client relationships