Poste et missions
Overall Purpose
To provide regulatory advice in relation to the UK Transfer Compliance team’s areas of responsibility to all business areas and support functions.
Compliance Controls:
1. Implement Compliance controls (using Head Office checklists and updating/creating control points relevant to UK business and regulations) to ensure a robust internal control system with Natixis London Branch affected entities.
2. Consult with the UK Head of Controls, UK Head of CIB Compliance, the UK Head of Compliance and the EMEA Head of Controls as appropriate.
3. Suggest/implement procedural and/or monitoring tools deemed necessary to carry out these controls.
4. Manage and take ownership in defining the remediation of corrective measures resulting from thematic and Compliance reviews. Ensure ownership, deliverables and timelines are clearly understood by action owners and that there is appropriate escalation of any delayed or overdue actions.
Targeted Testing:
5. Undertaking adhoc targeted testing to review identified areas of potential heightened risk.
6. Responsible for scoping the review parameters and undertaking the review.
PRA/FCA Senior Manager, Conduct Rules Regime (“SMCR”)
7. To liaise with the Human Resources Department (“HR”) to identify members of staff which require certification
8. To review requests to be Certified and Certified Persons applications · To review requests to be Senior Management Function applications
9. To liaise with UK Compliance management and HR on the review of the on-boarding policy and procedure
10. To verify all that all information relating to the certification and senior manager application process has been received and verified prior to certifying or submitting in the FCA/PRA portal
11. To verify that all the necessary CISI and Conduct Rules training have been completed prior to certifying
12. Liaise with HR for the correct completion of JDs and upload of required documents and information in the HR Comply tool
13. To liaise with HR and HR Comply on the development and enhancement of the tool and technical issues encountered
14. To inform certified staff of their de-certification when necessary
15. To maintain log of all certified staff
16. To complete the FCA Directory for any amendment to the Certified staff status
17. To liaise with the FCA in relation to discrepancies on the FCA Directory
18. To review and update the SMCR Policy and related procedures
19. To organise and provide SMCR training and briefings to London and any overseas-based staff caught by the UK regime.
Annual Re-certification process
20. To liaise with HR to identify staff which require re-certification
21. To assist in organising the annual re-certification exercise
22. To review the Compliance section of the Job Descriptions
23. To assist HR with Hireright training and competence questions when necessary
24. To review the Fitness and Proprietary and the Professional Conduct and Ethics forms
25. To follow up on the completion deadline of the Competence and Capabilities sign off by both staff and line managers
Training and Awareness
26. To liaise with Head Office, UK Compliance teams to coordinate an annual review of compliance education and awareness requirements for Natixis London staff and relevant overseas-based staff
27. To liaise with external training providers, Head Office, HROne and HR as required to ensure the roll out of required training.
28. To coordinate, follow up all training for Natixis London and related testing of training courses and content as appropriate
29. To liaise with the relevant with IT, HROne technical team and Head Office on technical issues affecting the completion of training for London Branch members of staff and relevant overseas-based Certified Persons
30. To liaise with HROne and Head Office to obtain the training completion report
31. To review list from Paris, to see if correct staff enrolled, list of MRTs etc.
32. To reporting to management as necessary
33. To track and assist with the communication of new and amended policies, bulletins, and regulatory news alerts to members of staff
34. To review and update the Compliance Education and Awareness Procedure document
Overseas visitors
35. To maintain a list of non-London Natixis staff that visit the UK for business purposes
36. To respond to queries relating to visits from Head Office and Business Lines
37. To follow up with the visitors to ensure that the visit complies with the Visitor’s policy
38. To undertake periodic monitoring of the travel list from Paris and Visitors’ log
39. To assist with the review of the Natixis London Branch Visitors Policy.
Gifts & Entertainment (“G&E”)
40. To review G&E disclosures, approve or escalate as necessary.
41. To liaise with Head Office in relation to the development of Odeon Ethics system for the PAD Module
42. To escalate G&E disclosures to the Financial Crime Team and the London ExCo as appropriate
43. To undertake periodic monitoring in relation to G&E disclosures
44. To review and update the Gift and Entertainment Procedure
45. To provide Management Information to the Financial Crime Team to allow it to perform its function in relation to the identification and prevention of Bribery and Corruption.
OBI and PA Dealing
46. To review all PA dealing and OBI requests, approve or escalate as necessary.
47. Approval of G&Es, PA Dealing new account and review of problematic PA Dealing requests
48. To liaise with Head Office in relation to the development of Odeon Ethics system for the OBI and PAD Module
49. To review and update the OBI and PAD Procedure
Incidents Threshold Crossings
50. To maintain the Incident Threshold Crossings Register and liaise with the EMEA Head of Conduct & Culture.
51. To review and update the Quarterly London Conduct Committee Deck in preparation for the Quarterly meetings.
52. To maintain all relevant incidents within the Conduct Tool.
Ad hocs
53. To assist the UK Head of CIB Compliance and senior management with ad-hoc tasks and projects that may be assigned from time to time
54. To attend the Fitness and Proprietary Committee as necessary
55. To train staff to use the Odeon Ethics tool
56. To liaise and work with Head Office MRT/GMFO requirements when necessary
57. To liaise and assist Internal Audit on all Central Compliance responsibilities
58. To deliver induction training to intern new joiners and to other new joiners
59. To assist with the provision of monthly management information to senior management
Legal and Regulatory responsibilities
60. To comply with all applicable legal, regulatory and internal compliance requirements as issued from time to time, including but not limited to: The London Compliance Manual, the FCA’s Conduct Rules, Compliance policies and procedures, Security policies and procedures, including but not limited to the prevention of Financial Crime and Fraud, including reporting obligations to the MLRO.
61. To develop regulatory knowledge to ensure ability to undertake the role.
62. To complete all mandatory training as required to attain and maintain competence
Key internal contacts
63. All UK staff/ Head Office Compliance/All overseas certified staff and their business lines management
Key external contacts
64. FCA/CISI/Training providers
Profil et compétences requises
Experience with dealing with professional ethics topics in a large investment bank
Experience of undertaking control reviews or other monitoring / testing experience
Strong Analytical skills · Good aural and written communication skills
Team player who can also work independently
Ability to deal with people of all levels