Job Title:                     Head of AML/KYC

Salary:                        £45K - £60K

Location:                    London

 

Job Purpose

  • Manage the Customer Verification team, and playing a leading role in the creation, implementation and delivery of policy to ensure that (AML), (CTF), (KYC) and Sanctions regulatory requirements are met at the on-boarding stage of new relationships and then continued during in-life management of relationships.
  • Act as the AML and financial crime lead ensuring that all areas of the business are compliant with relevant law and regulation.
  • To engage with staff across the business to ensure they have the skills and knowledge to best protect the business and its customers.
  • To engage with members (as required) to advocate for the policies and procedures adopted to secure compliance.

Key Responsibilities

Policies and procedures

  • Working with the Compliance Director to the creation and implementation of AML, KYC & Sanction rules including those relating to (PEPs)
  • Developing and delivering the financial crime policies and procedures to enable its compliance with regulatory requirements
  • Maintaining processes and procedures for EDD for high risk customers, as agreed with management and the MLRO and ensuring that a clear audit trail is maintained
  • Ensuring that AML, CTF, KYC & Sanctions related policies and procedures are complete, fit for purpose and reviewed annually in liaison with the MLRO

Advisory

  • Working with and advising the compliance director on AML activities, with recommendations or otherwise on the AML status of active customers
  • AML, KYC, CTF, PEP and Sanctions subject matter expert for the business and providing sign off to Customer Risk Assessments (CRA) drafted by the KYC team
  • Ensuring that clear and verified information on application ownership structures, including ultimate beneficial ownership, source of wealth are available and retained for audit & regulatory review purposes
  • Providing AML, KYC, CTF & Sanctions expertise to review new and amended regulation and legislation, to help highlight and implement requirements for the business.
  • Conducting gap analyses and making appropriate recommendation to remediate against AML, KYC, CTF & Sanctions regulatory requirements
  • Ensuring that financial crime intelligence is shared between all parts of the business
  • Liaising with and observing the requirements of the MLRO and supporting team in respect of all AML CDD, PEP and sanctions issues and requirements
  • Overseeing the hotline, to provide operational staff with support (on an exceptional basis) out of hours

Training

  • Developing the KYC team’s investigation skills and AML knowledge where appropriate
  • Preparing and presenting material for staff training and communications in liaison with the MLRO
  • Ensuring that all staff complete regular AML refresher training and that specific staff with higher level needs receive appropriate training

Reporting

  • Preparing all required reports, documentation and accurate management information for the Executive Board and Compliance Committee Meetings on AML, KYC, SARs & Sanctions related management information and reporting
  • Contributing to preparation of the MLRO annual report

Ongoing Monitoring

  • Undertaking daily checks of the KYC team’s work to ensure that decisions are of a consistently high quality and that any remedial actions required are identified and implemented in a timely manner
  • Monitoring and policing completion of all CDD/EDD requirements on approved cases with related conditions precedent
  • Ensuring that on-going alerts such as adverse media, PEP and sanctions hits and persons of special interest are reviewed on a timely basis and appropriate action taken
  • Maintaining, monitoring and executing periodic reviews to ensure that AML policies and controls are being observed
  • Reviewing business performance against SLAs, reporting non-compliance and devising and executing corrective action

Investigations

  • Leading the business with all AML, KYC, CTF & Sanctions related enquiries, including advising on the requirements of the appropriate regulatory regimes and resolving case related enquiries
  • Assisting with internal investigations in relation to SARs and implementing the AML compliance frameworks

Line Management

  • Manage the KYC team, ensuring all tasks, duties and responsibilities are handled in a timely, professional, accurate manner and consistently high quality manner
  • Continuous development for less experienced members of the team on financial crime and keeping oversight of the investigations and reviewing the worked cases

Risk Management

  • Using AML knowledge and experience to ensure the business is better protected from customers using the proceeds of crime
  • Liaison with staff across the business on AML, KYC, CTF and Sanctions related matters and establishing close working relationship with the KYC team
  • Building and maintaining strong relationships across the sector with external partners
  • Providing the business and its senior management with guidance and advice related to financial crime regulatory requirements
  • Using a risk based approach to review the AML and general Financial Crime risk landscape, governance and controls framework and report on and implement improvements with the agreement of the MLRO
  • Delivering the clearance of audit, operational risk and compliance related AML, KYC, CTF & Sanctions issues
  • Maintaining appropriate contacts at peer organisations through attendance at industry events
  • Horizon scanning for changes in regulation and legislation which will have an impact on business operations
  • Facilitating review and update of risk appetite in respect of AML, KYC, CTF & Sanctions

Knowledge/Experience:

  • A minimum of 5 years’ experience in a compliance/financial investigatory role
  • Detailed knowledge of the UK AML, KYC, CTF & Sanctions (and where applicable, overseas) regulatory regime and requirements
  • Knowledge of SAR’s and law enforcement requirements
  • Experience of dealing with and identifying money laundering techniques and its associated crimes
  • Experience of undertaking and leading financial crime investigations
  • Enhanced knowledge of AML, CTF and Tax evasion
  • Knowledge of overseas AML high risk and non-equivalent countries and territories
  • Practical knowledge and experience of commonly deployed anti money laundering systems
  • Knowledge and experience of drafting AML, KYC, CTF & Sanctions policies and procedures
  • Knowledge and experience of analysing information provided in support of CRAs and providing approval of such

Qualifications:

  • AML Investigator (completed or in progress) desirable.
  • Financial intelligence officer or similar (completed or in progress) desirable.
  • PML (from the Gambling Commission) holder desirable

Key competencies:

  • Excellent written and oral communication skills
  • Confident interacting with staff at all levels of the business up to senior management level and providing appropriate level of constructive challenge to information provided for assessment
  • Able to advocate for the AML/KYC risk approach adopted when dealing with members
  • Excellent data analysis skills
  • Ability to prioritise tasks, deliver to a consistently high standard while managing competing deadlines, proactive problem solver
  • Customer focused and risk aware

 

To discover more contact Steven Jackson on steven@grs-recruit.com