Description of the Business Line or Department
The Compliance Service Unit (CPLE) is responsible for the definition and consistency of the compliance risk prevention and control system, and for coordinating the framework aimed at preventing, identifying, assessing and controlling reputational risk.
In conjunction with the Business Units and other Service Units (BU/SUs), CPLE performs the following tasks with respect to compliance risk:
- defining and implementing the overall normative framework of the Compliance service and monitors its implementation;
- defining procedures and implementing a framework to ensure compliance with respect to compliance risks;
- awareness-raising among Group employees regarding compliance risk and the strengthening of the compliance culture within the Group;
- mapping and analysing Group compliance risk and general vigilance regarding issues likely to harm the Group's reputation or that of one of its activities;
- performing the second-level control and supervision of the framework, including independently assessing compliance risk management within the entities/activities with a major impact on the Group's risk profile, and individually with respect to regulated employees, in compliance with the applicable regulations;
- monitoring relations with supervisory and regulatory authorities, and representing the Societe Generale Group to these authorities, not including supervisory and regulatory authorities where the Legal function (SEGL/JUR) organises and coordinates the monitoring of these relations, in particular the Autorite de Controle Prudentiel et de Resolution (ACPR) and the European Central bank (ECB);
- consolidating and monitoring significant compliance events in the entities.
Summary of the key purposes of the role
The Swap Dealer Compliance Office is a team located in the UK and part of the Société Générale London Branch team which is also functionally linked to the Wholesale Market Integrity Division in Paris.
The Swap Dealer Compliance has 2 main roles:
- Dodd-Frank Title VII (DFA): The Swap Dealer Compliance Office is responsible for the ongoing compliance oversight of the implementation and management of the Swap Dealer Compliance Program with the CFTC and the Security-Based Swap Dealer Compliance Program with the SEC for SG entities impacted: Société Générale SA (registered with both CFTC and SEC) and Société Générale International Limited (registered with the SEC).
- Other OTC derivatives regulations: The remit of the team has recently been extended to cover the OTC derivatives regulations equivalent to DFA such as EMIR, SFTR. The team will provide compliance oversight and advisory on those regulations for the UK perimeter while working closely within the team with DFA SMEs and Paris EMIR/SFTR SMEs.
The role holder will be primarily responsible:
- Provide day-to-day regulatory advice to UK Business Unit and Support Unit on EU / UK OTC derivatives regulations (EMIR mitigation risk techniques, EMIR margin requirements, EMIR reporting, amendments from EMIR REFIT such as FRANDT, SFTR reporting) including contribution to compliance regulatory assessment on new product/initiative
- Act as the primary compliance representative in the UK on regulatory projects linked to those regulations by providing regulatory rules interpretation, contribution to regulatory impact assessment and regulatory guidance as and when required. A particular focus would be required on EU/UK divergences for EMIR and SFTR.
- Develop and draft the compliance owned normative documentation, e-learning, live training session as well as performing on an ad-hoc basis training awareness of those regulations, or coordinate those with the Paris team to take UK divergences in global training or framework if relevant.
Summary of responsibilities
- Advice, support and assist SGLB and SGIL, including compliance advisors of the various business and support functions, on matters related to OTC derivatives regulations (primarily EMIR, SFTR) by: (i) proactively providing compliance advice to and answer compliance queries, (ii) overseeing complaint handling investigation and resolution, (iii) providing compliance opinion as part of New Product Committees, (iv) reviewing marketing materials and ensuring they are compliant (when required), (v) establishing and maintaining a constructive, open relationship and dialogue with stakeholders in business unit and support unit, (vi) participating in projects to ensure that SGLB and SGIL are prepared for any required changes as a result of new regulatory developments or UK/EU divergences, (vii) assessing the level of regulatory and reputational risks associated with SGLB/SGIL transactions, projects or products and escalating to the appropriate governance for decision-making in accordance with the risk-based approach set out in the policies.
- Contribute to the identification of SGLB/SGIL regulatory obligations and changes to those by (i) identifying regulatory obligations related to OTC derivatives regulations (EMIR mitigation risk techniques, EMIR margin rules, EMIR reporting, amendments from EMIR REFIT such as FRANDT, SFTR reporting), (ii) analysing regulatory developments related to those regulations, (iii) assessing the impact of these developments on SGLB/SGIL.
Particular attention will have to be made to the coming SFTR revised validation rules, Implementation of new phase of Initial margin requirements under EMIR, Coming EMIR REFIT requirements with FRANDT requirements, revised EMIR reporting regulation involving the extension to a higher number of fields and data to report, and more information linked to the life cycle of transactions, and other regulatory changes that may arise.
- Contribute to the assessment of compliance risk within SGLB and SGIL by assessing the compliance risk related to OTC derivatives regulations (EMIR, SFTR on the above-mentioned requirements) as part of the annual exercise (both inherent risk and residual risk after mitigation).
- Raise awareness to SGLB and SGIL staff, on compliance risk by (i) communicating regulatory changes and news, (ii) designing and delivering compliance training, (iii) actively encouraging a culture of compliance.
- Contribute to SGLB and SGIL Compliance policies and procedures framework by providing compliance expertise in the drafting of the Compliance policies and procedures following under the team’s perimeter.
- Identify, investigate, and report compliance breaches and incidents related to the team’s perimeter.
- Attend and represent SG at appropriate industry working groups on regulatory development topics as appropriate.
- Contribute to the production of reporting for the local SGLB Management Committees and SGIL governance, including at Board level.
- Work closely with the Central team in Paris on common topics and projects related to those requirements.
- On a longer term develop knowledge in the DFA swap dealer requirements, similarly to the rest of the team developing some knowledge on EMIR and SFTR requirements to be able to build back-ups within the team.
Level of Autonomy and Authority
The post holder will be a trusted advisor and therefore will have sufficient authority to advise the Business Unit and Service Unit on a day-to-day basis. In collaboration with other support and control teams the post holder will determine how best to deliver the responsibilities set out above, within a compliance advisory framework appropriate to SGLB and SGIL.