The Head of Compliance & MLRO (“HCM”) has responsibility for overseeing the identification, measurement,
management and reporting of compliance and conduct risk, anti-money laundering, terrorist financing and
proliferation financing risks (“AML/CTF/PF”), sanctions, prevention of financial crime including fraud, anti-
bribery and corruption, tax evasion and market abuse. Acting as second line of defence and also undertaking
the statutory responsibility of money laundering reporting duties. The HCM is also responsible for the
oversight of know your customer (KYC) process throughout the Bank.
The role supports the UK to deliver the Business Plan and strategic objectives within the context of
regulatory and legal requirements, and that all commercial decisions e.g. product, market, geography,
customer, scope or process, receive appropriate regulatory consideration.
Key Responsibilities include:
Providing timely, accurate, and relevant regulatory advice, guidance and oversight to on
compliance risks/matters.
Serving as a first point of contact for all staff in the Bank for compliance advice, guidance and insight
into regulatory issues.
Providing accurate and timely MI to the Board, Risk & Compliance Committee (“BRCC”) on a
quarterly basis and on a regular basis to the relevant EXCO Committees.
Informing staff of the compliance policies and procedures in place and communicating the impact
of changing legislation/ regulation and the effect on the Bank’s compliance policies, which may
affect current business and future business development.
Ensuring effective strategic and tactical compliance policies are developed and applied, with
supporting procedures, and end to end processes put in place.
Identify, assess, measure and report compliance risks and deal efficiently with it.
Identify and investigate breaches of legal and regulatory requirements, compliance policies and
procedures and ensuring that such breaches are appropriately rectified with the implementation of
suitable remediation plans.
Delivery of a risk-based compliance monitoring programme to enable the senior management to
effectively understand, manage, monitor, and mitigate the Bank’s various compliance and regulatory
risks and that an assurance process is in place to oversee this.
Proactive maintenance, management and update of the Bank’s compliance policies,
procedures and documentation in light of any statutory and regulatory developments.
First point of contact for Regulators and statutory bodies on compliance risk matters and ensuring an
open and honest regulatory relationship is maintained with the regulators at all times.
Working closely with senior management to develop and instil a compliance culture or mind-set across
the Bank providing strong compliance leadership in the Bank. Ensuring that compliance policies and
procedures are embedded in the business.
Providing compliance education and training for staff, supported by policies and procedures and other
documents including compliance manuals, internal codes of conduct and practical guidelines.
Making sure all relevant staff remain aware of their corporate and personal regulatory obligations,
responsibilities and accountabilities.
Managing and supervising the activities of other compliance function staff – Regulatory
Compliance Manager, Compliance Managers and Head of KYC
Ensuring, from a compliance and MLRO perspective, that the UK successfully maintain its
Regulatory authorization/s.
Ensuring that, in cases of planned absence from the office, responsibilities are delegated to approved,
deputy nominated cover for the role ensuring they are trained sufficiently in advance on the tasks and
responsibilities involved, including providing handover
documentation to enable the replacement member/s of staff execute the role successfully.
Participation in and involvement in training and development initiatives as directed by Head of HR and
the Chief Executive Officer.
Input into the Senior Managers & Certification Regime process, implementation, ongoing review and
update in light of future developments.
Developing and promoting a robust conduct risk culture across the Bank.
Completion of an annual MLRO report to the Board of Directors which also includes an overview of the
effectiveness of the Bank’s systems and controls around whistleblowing.
Overseeing the firm’s compliance with AML/CTF/PF, Fraud, Sanctions, tax evasion, Bribery and
Corruption and Market Abuse regulations.
Management of the Bank’s AML/CTF/PF processes including the design, set up and
implementation of internal AML/CTF/PF procedures and policies, including customer due
diligence measures, reporting, record-keeping, risk assessment, management and control
systems.
Assist Operations with the onboarding of third parties both at onboarding and periodic review for
financial crime risks, procurement and operational resilience (where applicable). Engage with various
business units to enhance operational resilience and Third-Party Risk Management practices, including
proper documentation in Risk and Control Self-Assessments (RCSAs).
Organising and arranging AML/CTF/PF training of the Bank's staff and ensuring staff complete
relevant training.