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As the AML and High-Risk Technical Specialist, you will operate within our first‑line operational teams, delivering client‑centric services while ensuring strict adherence to our regulatory framework. You will play a key role in applying our risk appetites and frameworks, ensuring that client risk, across both standard and higher‑risk profiles, is consistently identified, assessed, and effectively managed. Higher‑risk applications require enhanced scrutiny, and the Group’s High‑Risk Committee (HRC) provides governance and oversight for these cases. The role includes delegated authority to approve certain applications directly and responsibility for preparing comprehensive submission packs and presenting them to the HRC when escalation is required. You will work collaboratively with New Business, Technical Support, Business Development, and Payments teams, as well as engage with clients where appropriate. Close partnership with the MLRO and Risk & Compliance teams is essential to ensure that client onboarding and periodic reviews meet all regulatory and internal policy requirements.
Job Responsibility:
Act as a subject matter expert across AML, with specialist focus on higher‑risk client segments
Champion CIL’s AML and CFT policies and procedures always
In partnership with the Financial Crime Team, develop, implement, and maintain AML procedures and controls to ensure regulatory compliance
Maintain up‑to‑date knowledge of AML legislation, regulations, and relevant guidelines
Drive best practices for AML/CFT risk identification, assessment, and ongoing monitoring
Uphold robust internal control standards and ensure timely closure of internal and external audit actions
Conduct comprehensive, risk‑based due diligence to verify client identities and assess money‑laundering risk
Maintain and update client profiles to reflect changes in risk factors
Analyse and understand complex corporate and trust structures, identifying all relevant connected parties
Provide approval and analytical commentary for account opening and periodic review processes
Implement and oversee transaction‑monitoring systems to detect unusual or suspicious activities
Stay informed on regulatory changes, industry developments, and emerging financial‑crime trends, updating training content accordingly
Contribute to risk‑mitigation strategies and enhancements to AML controls
Co‑develop and maintain the AML Accreditation Programme, delivering training and guidance to operational teams
Collaborate with the First Line Assurance team to ensure assessment standards align with regulatory expectations
Provide day‑to‑day guidance on new client applications and engage directly with clients as needed
Analyse transaction patterns and trends, escalating insights to the Financial Crime Team and relevant stakeholders
Prepare reporting for the HRC and Executive & Investment Risk Committees
Produce ongoing progress reports related to file reviews
Act as the first‑line representative on AML/CFT‑related projects arising from compliance monitoring and regulatory change
Operate in accordance with the delegated authority framework provided by the HRC
Critically assess new higher‑risk applications, with particular focus on Source of Funds/Source of Wealth, purpose, expected activity, PEPs, adverse media, and structural complexity
Maintain the CIL Investment PEP Register, ensuring all decisions are accurately recorded
Manage the Investment Operations Delegated Authority Register
Hold overall responsibility for the Business Risk Assessment (BRA) and Technology Risk Assessment (TRA), including periodic review and reporting to ExCo and the Board
Requirements:
A minimum of five years’ experience in regulated financial services
strong investment‑industry knowledge is advantageous
Detailed understanding of Isle of Man AML/CFT legislation, regulation, and guidance, particularly in the context of higher‑risk clients
Experience analysing complex corporate structures and determining associated due‑diligence requirements
Advanced competency validating Source of Funds and Source of Wealth using independent sources
Strong knowledge of governance, risk and control frameworks
familiarity with the 3 Lines Model is essential
Proficiency with analytical tools, data‑analysis methods, and reporting techniques
Strong analytical, research, problem‑solving, and communication skills
Ability to evaluate information through a risk lens and present clear, concise analyses to senior stakeholders
Proven ability to work both independently and collaboratively, building relationships across functions
Sound judgment, decision‑making capability, and the ability to influence others
Strong organisational skills, with the ability to manage multiple priorities in a dynamic environment
Forward‑looking and strategic mindset, contributing to business planning and execution