Head of Compliance & MLRO

As Head of Compliance (SMF16)

• Lead and continuously enhance the UK Compliance Framework, including policies, procedures, governance and controls relating to Consumer Duty, conduct risk, market abuse, transaction reporting, conflicts of interest, personal account dealing, financial promotions, product governance and client assets.
• Lead the Compliance team's handling of customer complaints and set the firm's complaints-handling policy.
• Serve as a member of the UK Executive Committee, contributing to strategic decision making while ensuring that regulatory considerations and good customer outcomes are embedded across the business.
• Prepare and present regular Compliance and Consumer Duty reports to the UK Board, Executive Committee and relevant governance committees, providing clear insight into regulatory risks, customer outcomes, emerging issues and the effectiveness of the UK Compliance Framework.
• Identify owners for the company's regulatory returns and ensure they are prepared and submitted accurately and on time.
• Act as the firm's primary point of contact with the FCA, coordinating notifications, periodic updates, and responses to regulatory, legal and law enforcement enquiries.
• Run horizon scanning for upcoming regulatory change and translate it into firm policy.
• Provide strategic regulatory advice and challenge on new products, product governance, business initiatives, outsourcing arrangements, acquisitions, major projects and regulatory change, ensuring that conduct risks and good customer outcomes are addressed from the outset.
• Provide second line oversight and regulatory challenge in relation to the firm's Consumer Duty and Operational Resilience frameworks.
• Working closely with Group Assurance, develop the risk based Compliance Monitoring Programme and oversee its effective execution, escalation of findings and timely remediation, while ensuring that UK Compliance policies and procedures remain current and effective.
• Design and deliver regulatory training across the business.
• Maintain the firm's breach register and report significant breaches to the FCA.
• Lead or oversee investigations into regulatory breaches, compliance incidents and financial crime matters, ensuring timely escalation, remediation and regulatory reporting where required.
• Maintain the Conflicts of Interest Register and lead the identification of new conflicts.
• Build and oversee systems and controls to detect and prevent market abuse by clients, including STOR disclosures to the FCA.
• Own the effective operation and second line oversight of daily EMIR and MiFIR reporting, including MDP monitoring, and ensure that reporting errors and omissions are investigated, remediated and notified to the FCA where required.
  Consult with and inform the CASS Office on CASS breaches, incidents and related MI, in line with the CASS Breach and Escalation Policy.
• Lead, develop and mentor the UK Compliance team, with responsibility for its day to day priorities, resourcing, performance and ongoing development.
• Work collaboratively with Group Compliance, Group Financial Crime, Group Assurance, Risk, Legal, Internal Audit and business stakeholders while retaining responsibility for the oversight and effectiveness of the UK Compliance Framework.

As Money Laundering Reporting Officer (SMF17)

• Hold FCA approval as MLRO for the UK entity and fulfil the Prescribed Responsibilities for financial crime under SMCR.
• Report regularly to the UK Board and governance committees on financial crime risk.
• Prepare and present the annual MLRO Report and regular financial crime reporting to the UK Board and relevant governance committees, providing an independent assessment of framework effectiveness, material risks, management information and required enhancements.
• Act as the primary contact with the FCA and UK law enforcement on financial crime matters.
• Receive, assess and decide on internal Suspicious Activity Reports, including DAML SARs, and determine when to escalate to the National Crime Agency.
• Maintain clear records of SAR decisions and rationale.Working closely with Group Financial Crime, oversee the effective implementation and ongoing operation of the UK AML, CTF and CPF Framework, including the Business Wide Risk
• Assessment and Customer Risk Assessment methodology, while retaining accountability for its effectiveness within the UK business.
• Provide independent second line oversight of customer due diligence, enhanced due diligence, onboarding, ongoing monitoring, transaction monitoring and high risk client review and escalation processes operated by the first line.
• Own the UK sanctions compliance programme and ensure alignment with OFSI requirements.
• Design and oversee the AML/CTF training programme so staff receive role-appropriate financial crime education.
• Working with Group Financial Crime, Group Assurance and Internal Audit, lead or oversee financial crime monitoring and thematic reviews and ensure that related findings and remediation actions are completed effectively and on time.

Requirements

• Current or recent approval as SMF16 and/or SMF17 (or directly equivalent Senior Manager Function experience) at an FCA-regulated firm.
• Significant experience leading a Compliance function within an FCA regulated investment firm, ideally involving retail investment services, CFDs, spread betting, brokerage or another trading environment. Experience in fintech, payments or electronic money would also be advantageous.
• In depth knowledge of the UK regulatory framework, including FSMA, the FCA Handbook, SMCR, Consumer Duty, UK MAR, MiFIR, EMIR, the Money Laundering Regulations 2017, POCA, the Terrorism Act, the UK sanctions regime and relevant FCA guidance, including SYSC 6.1.1R and the Financial Crime Guide.
• A track record of managing SAR submissions to the NCA and running a firm's sanctions and financial crime programme.
• Demonstrable experience designing, implementing and enhancing Compliance Frameworks, overseeing Financial Crime Frameworks and Business Wide Risk Assessments and preparing Board level Compliance and MLRO reporting.
• Strong understanding of Consumer Duty, retail conduct, product governance, market conduct, transaction reporting, CASS and Operational Resilience requirements.
• Experience developing and overseeing risk based Compliance Monitoring Programmes and driving effective remediation of regulatory issues.
• Proven experience building constructive relationships with the FCA and Boards, including leading supervisory engagement, regulatory reviews, notifications, submissions, applications and other material regulatory correspondence.
• Proven leadership and people management experience, including building, developing and motivating a high performing Compliance team and supporting professional development and succession planning.
• Outstanding written, verbal, presentation and stakeholder management skills, with the credibility to provide independent challenge and translate complex regulatory requirements into clear, practical and commercially proportionate business guidance

 

Nice to Have

• Experience covering both Head of Compliance and MLRO functions in a single role.
• Background in CFDs, brokerage, fintech or payments.
• Experience with automated onboarding and digital KYC tools.
• CAMS, ICA, ACAMS or an equivalent compliance or financial crime professional qualification.