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:

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

(Position Filled) Head of AML/KYC - London - £45K - £60K