MLRO and Compliance Officer
Skills
About This Role
Role purpose
The MLRO and Compliance Officer is the firm’s designated controlled-function holder for AML/CFT oversight and wider regulatory compliance oversight, for a QFC/QFCRA firm. The role is responsible for overseeing implementation of the firm’s AML/CFT policies, procedures, systems, and controls, acting as the central AML/CFT contact point with authorities, receiving and assessing internal suspicious transaction reports, determining whether to file suspicious transaction reports with the FIU, and reporting regularly to senior management. The role also oversees the firm’s broader compliance framework, including monitoring compliance with applicable laws, regulations, rules, and internal policies; advising the business and senior management on regulatory obligations; supporting a sound compliance culture; and escalating material compliance issues.
Key responsibilities
- Oversee implementation of the firm’s AML/CFT policies, procedures, systems, and controls in relation to the QFC, including operation of the firm’s risk-based approach.
- Ensure that AML/CFT policies, procedures, systems, and controls are developed, maintained, monitored, and regularly reviewed for effectiveness.
- Receive, investigate, and assess internal suspicious transaction reports and determine whether suspicious transaction reports should be made to the FIU.
- Make suspicious transaction reports to the FIU and notify the Regulator where required.
- Act as the firm’s central point of contact with the FIU, the QFCRA, and other State authorities on AML/CFT matters, and respond promptly to requests for information.
- Receive and act on governmental, regulatory, and international findings relevant to AML/CFT, and bring regulatory guidance to senior management’s attention.
- Monitor the appropriateness and effectiveness of the firm’s AML/CFT training programme and recommend improvements where needed.
- Report to senior management on AML/CFT issues at such intervals as senior management determines and on the MLRO’s own initiative where necessary.
- Prepare and submit the annual MLRO report to senior management and support completion of any written confirmation and action plan required by the Regulatory Authority.
- Keep the Deputy MLRO informed of significant AML/CFT developments and ensure continuity arrangements are effective.
- Oversee implementation and ongoing effectiveness of the firm’s compliance policies, procedures, systems, and controls across its regulated activities.
- Advise senior management, the Governing Body, and relevant business functions on applicable legal and regulatory requirements and on the firm’s obligations under the QFCRA framework.
- Develop, maintain, and execute a risk-based compliance monitoring programme and report findings, recommendations, and remediation progress to senior management.
- Monitor regulatory developments relevant to the firm’s business, assess their impact, and support timely implementation of any required changes to policies, procedures, controls, or practices.
- Review new products, services, business initiatives, outsourcing arrangements, and material changes to the firm’s operations from a compliance perspective, and provide recommendations as appropriate.
- Maintain appropriate compliance records, registers, and evidence of monitoring, breaches, incidents, attestations, and remedial actions, as applicable to the firm’s business.
- Escalate material compliance breaches, control weaknesses, or regulatory issues promptly to senior management and, where appropriate, the Governing Body / Board and the Regulator.
- Support delivery of compliance training and awareness across the firm so as to promote a sound compliance culture and understanding of regulatory obligations.
- Coordinate with other control functions and relevant business areas to support effective governance, issue remediation, and ongoing regulatory compliance.
- Person qualifications
- Fit and proper to hold QFCRA controlled functions.
- Sufficient seniority, knowledge, experience, authority, and understanding of AML/CFT and regulatory compliance requirements to discharge the role effectively and independently.
- Previous compliance/MLRO/Internal Audit/Legal experience of at least 3 years (from any jurisdiction) is required.
- Specific QFCRA certification will be required and can be obtained prior to taking up the role.
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