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Greater London, England, United Kingdom
Hybrid
Not Available
Job Brief
MBSCL is establishing its own dedicated, independent Compliance function as it moves through FCA authorisation to provide regulated financial advice. This role holds the SMF16 (Compliance Oversight) and SMF17 (Money Laundering Reporting Officer) functions for MBSCL, and is a distinct individual from the equivalent functions at Digital Moneybox Limited (DML) - independence from DML is a deliberate feature of this role, not an administrative detail.
DML is the main Moneybox operating business: it runs the app and digital platform, and provides the savings, investment and pension products Moneybox customers use day to day. MBSCL’s is a separate entity set up to provide regulated financial advice to those same customers. DML acts as a supplier to MBSCL under an intra-group agreement, providing the platform, customer onboarding, and a range of shared services (including IT, finance, HR and customer support) that MBSCL relies on to operate.
You will report to the MBSCL SMF1 for day-to-day business partnering, with a direct line of accountability to the MBSCL Board for the discharge of the SMF16 and SMF17 functions specifically, to preserve genuine independence. As part of working in a matrix group, you will also be part of the broader Risk and Compliance team and have a dotted line to the VP of Risk and Compliance for the Moneybox Group. This is a newly created role and includes oversight of the intra-group agreement with DML, compliance advisory support to the advice business, and compliance oversight (including the controls around the Aurora advice engine).
In your first six to twelve months, you'll focus on standing up the compliance function (including MBSCL’s independent financial crime framework), establishing effective oversight of the intra-group agreement with DML, and building the working relationships with MBSCL's co-sourced second line financial crime partner and outsourced internal audit provider that let MBSCL demonstrate genuine, evidenced independence to the FCA.
Hold the SMF16 (Compliance Oversight) function, running MBSCL's compliance monitoring programme and regulatory advice, to ensure MBSCL meets its FCA obligations.
Hold the SMF17 (Money Laundering Reporting Officer) function, owning MBSCL's Financial Crime framework and suspicious activity reporting, to protect MBSCL and its customers from financial crime.
Own MBSCL's Customer Due Diligence model under the Money Laundering Regulations 2017 to onboard customers compliantly.
Direct and challenge MBSCL's co-sourced second line financial crime partner, to ensure their review genuinely tests MBSCL's own controls rather than DML's.
Provide independent compliance oversight and challenge of the intra-group agreement with DML, to evidence effective, continuing oversight of the functions MBSCL receives from DML.
Provide compliance oversight and challenge of the controls around the Aurora advice engine and House Rules, working with the Director of Advice, to ensure suitability and evidence requirements are met.
Provide pragmatic, timely compliance advice to the business, particularly the advice team, on COBS 9A suitability and Consumer Duty, to support good customer outcomes.
Report to the MBSCL Board, Audit & Risk Committee and Executive Committee on compliance and financial crime matters, to give senior stakeholders clear, decision-ready oversight.
Act as MBSCL's primary point of contact with the FCA on compliance, financial crime and authorisation matters, to support a smooth and credible regulatory relationship.
Lead horizon scanning, regulatory change and training for MBSCL, to keep the business ahead of regulatory developments.
You're comfortable being the named, accountable, independent voice for a smaller regulated entity operating alongside a larger group.
You have the judgement and confidence to escalate and challenge DML directly where MBSCL's interests require it, even under time pressure.
You can explain complex regulatory structures - CDD, reliance, outsourcing - simply and calmly to the Board and to the FCA.
You direct co-sourced and outsourced partners effectively without losing sight of your own personal accountability for the outcome.
You're pragmatic and diligent, comfortable operating in a fast-moving, pre- and early-authorisation environment.
Minimum 10 years in financial services compliance and/or financial crime, including experience as, or working closely with, an SMF16 and/or SMF17 holder.
Direct experience of Customer Due Diligence, reliance arrangements (regulation 39 MLR 2017) and/or group-wide AML policies (regulation 20), ideally within a group containing more than one regulated entity.
Experience overseeing intra-group or outsourced arrangements with the rigour of third-party oversight; familiarity with SYSC 8 is a strong plus.
Strong working knowledge of COBS 9A suitability requirements and Consumer Duty (PRIN 2A).
Experience supporting an FCA authorisation process, a skilled persons (s166) review, or comparable significant regulatory engagement.
Excellent stakeholder management skills, including direct experience reporting to Boards and Committees and interacting with the FCA.
Fluency in English.
Opportunity to join a fast-growing, award-winning and super ambitious startup.
Work with a friendly team of highly motivated individuals.
Be in an environment where you are listened to and can actually have an impact.
Thriving collaborative and inclusive company culture.
Company pension scheme.
Company bonus scheme.
Hybrid working environment.
Home office furniture allowance.
Personal Annual Learning and Development budget.
Private Medical Insurance.
Health Cash Plan - cashback on everyday healthcare like dental and opticians.
Cycle to work scheme - spread the cost of a new bike and accessories.
CycleSaver - save on bike-share subscriptions and have a more sustainable commute.
Wellhub subscription to a variety of gyms and wellbeing apps.
Enhanced parental pay & leave.
25 days holiday + bank holidays with additional days added with length of service.
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