As Senior Manager – Compliance, the role holder will provide senior regulatory expertise and second-line oversight across the UK Branch. The role supports and deputises for the Head of Compliance & MLRO, ensuring that regulatory risks are identified, managed and escalated appropriately, and that the Branch continues to meet FCA and PRA expectations.
The role includes responsibility for regulatory advisory support, thematic oversight, compliance monitoring, regulatory engagement and senior stakeholder interaction.
Compliance Responsibilities
* Responsibility for overseeing and embedding the Consumer Duty (PRIN 2A) within the UK business, including foreseeable harm identification, outcomes monitoring, vulnerable customer considerations, MI challenge, and escalation of poor customer outcomes.
* Leading on Investigating and responding to Regulatory authorities and FCA enquiries.
* Investigating and responding to internal enquiries relating to potential compliance risks/breaches
* Oversight of client categorisation and segmentation processes, including governance over Professional Client elections, ongoing appropriateness, record-keeping, and regulatory challenge where mis-classification risk is identified
* Reporting the relevant indicators for any incidents handled by the team to the relevant stakeholders
* Leading on and creating bespoke training and guidance to the business as the regulatory landscape evolves due to rule changes and/or guidance issued by the UK regulator
* Monitoring UK regulatory developments and assessing the impact on the London Branch
* Reviewing, maintaining and execute the risk-based Compliance monitoring programme
* Reviewing and submitting FCA/PRA required reporting via Reg Data/Connect
* Reviewing and monitoring recordings and reporting any anomalies or breaches
* Reviewing, maintaining and creating respective controls surrounding the following items:
* Personal Account Dealing
* Conflicts of Interest
* Financial Promotions
* Breaches
* Gifts & Hospitality
* Market Abuse
* Client Categorisation
* Whistleblowing
* Vulnerable Customers
* Code of Conduct (London centric version)
* Customer Complaints
* Presentations
* Obligations register (MyCompliance)
* Oversight and challenge of the Branch’s Single Customer View (SCV) framework, including data integrity, aggregation logic, exclusion handling, testing results, remediation actions, and evidential readiness for PRA/FCA or FSCS request
* Providing second-line assurance over the Branch’s FSCS compliance, including depositor eligibility, aggregation rules, exclusions, and alignment to PRA depositor protection requirements
* Collate MI for Branch Risk (BRC) and Executive Committee (ExCo)meetings
* Leading compliance on Regulatory projects
* Oversight and challenge of the Branch’s AEOI (FATCA / CRS) compliance framework, including classification logic, reporting accuracy, issue remediation, governance, and interaction with Group processes impacting UK regulatory obligations
* Ensuring the maintenance of robust regulatory evidence, MI, and audit trails to support FCA/PRA supervisory engagement, s166 reviews, and internal/external audit activity
* Oversight and regulatory challenge of the Branch’s Financial Promotions framework, including approval governance, ongoing monitoring, record-keeping, and compliance with FCA requirements on fair, clear and not misleading communications, financial promotion sign-off, and ongoing distribution controls
* Providing second-line oversight and challenge in respect of Best Execution obligations, including governance arrangements, execution policies, monitoring outcomes, escalation of deficiencies, and alignment with FCA expectations under COBS
* Oversight and challenge of the Branch’s Suitability and Appropriateness frameworks, ensuring that investment advice, discretionary and non-discretionary services, and execution-only activities comply with FCA requirements, including suitability assessments, appropriateness testing, disclosures, record-keeping and ongoing monitoring
* Ensuring that Suitability, Appropriateness, Best Execution and Financial Promotions considerations are properly embedded within the Branch’s Consumer Duty outcomes monitoring, including identification of foreseeable harm, MI review, and escalation of poor customer outcomes
* CIMS updating and providing evidence for resolved issues
* Responsible for the Compliance Policies and associated procedures
* Must have a thorough understanding of:
* Deposit-taking regulatory obligations, including Depositor Protection Rules, FSCS eligibility, deposit aggregators, exclusions, client segmentation and classification, and the interaction of these requirements with PRA and FCA supervisory expectations,
* Payment Services,
* Senior Managers & Certification Regime (SMCR),
* The wider SYSC rules to assess the impact of proposed changes to them,
* Financial Promotions regulatory requirements, including approval arrangements, ongoing monitoring, governance over promotions issued or approved by the Branch, and the interaction with Consumer Duty expectations,
* Best Execution requirements under COBS, including execution policies, oversight of execution quality, monitoring arrangements and regulatory expectations for second-line challenge,
* Suitability and Appropriateness requirements, including the regulatory distinctions between advised, non-advised and execution-only services, appropriateness testing, suitability assessments, disclosures, and evidential record-keeping,
* The interaction between Suitability, Appropriateness, Best Execution and Consumer Duty, including outcomes-focused supervision and foreseeable harm considerations.
* Good understanding of the wider FCA and PRA handbooks
* Be proficient in creating and executing Compliance Risk Assessments
* Good understanding of how to create and execute Regulatory Gap analysis
* Be proficient in creating, drafting framework documents, policies, procedures
* Providing senior advisory and deputised support to the Head of Compliance
* Responsible for ensuring the UK business is kept up to date with Regulatory Developments
* Assessing and reporting to senior management on how regulatory changes will impact the Branch
* Provide guidance to broader Group Compliance on UK changes where required
* Deputise for the Head of Compliance in their absence
Skills / Attributes Required
* 10+ years’ experience in a similar environment
* Technically proficient in the FCA principles and rules, in relation to SMCR and COBS
* Demonstrable understanding of SCV requirements, FSCS depositor protection rules, and PRA supervisory expectations for depositor data accuracy and mobilisation
* Strong working knowledge of the Consumer Duty framework, outcomes testing, and second-line oversight expectations for retail and private banking activities
* Strong working knowledge of FCA requirements relating to Financial Promotions, Best Execution, Suitability and Appropriateness, and the application of these requirements within a private banking, wealth management and investment services environment
* Demonstrable ability to provide effective second-line oversight and regulatory challenge in relation to investment-related conduct risks, including Financial Promotions, Suitability, Appropriateness and Best Execution
* Ability to interpret and apply FCA rules in a Consumer Duty context, ensuring that customer outcomes are monitored, MI is appropriately challenged, and issues are escalated where harm or poor outcomes are identified
* A legal and or compliance or regulatory background, preferably within the financial services industry
* Excellent written and verbal communication skills, with the ability to translate regulatory requirements into clear business guidance
* Strong analytical skills, attention to detail and the ability to work effectively under pressure
* Strong team player
* A professional with a business attitude in the workplace
* Action-oriented with a strong focus on completing tasks with accuracy and efficiency while working independently and with minimum direction