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An exciting opportunity has arisen for an experienced Financial Crime Manager to play a leading, hands-on role in the design, implementation and ongoing effectiveness of the Financial Crime framework across our investment and banking activities. The successful candidate will also hold Deputy Money Laundering Reporting Officer (DMLRO) responsibilities. The role encompasses responsibility across the following Group entities, to the extent required by regulation, legislation and Group Policy: Isle of Man Financial Services Authority regulated entities - Capital Financial Markets Limited (“CFM”) – Class 2; Capital International Limited (“CIL”) – Classes 2 and 3; and Capital International Bank Limited (“CIB”) – Class 1.2 (including South African Representative Office licensed by the SARB Prudential Authority). This role is first and foremost a Financial Crime Manager position, responsible for the day-to-day oversight, control, assurance and continuous improvement of the AML/CFT, sanctions and broader financial crime control environment and the co-ordination of the second line financial crime related activities which underpin the first line / second line partnering model. The focus will be to promote compliance with Isle of Man (and other applicable) law and regulation.
Job Responsibility:
Support in managing the end‑to‑end Financial Crime framework, ensuring compliance with relevant Isle of Man AML/CFT legislation and Codes, IOM FSA regulatory requirements and guidance, and applicable local, UK, EU and international Sanctions regimes
Provide support in the maintenance and enhancement of Financial Crime policies, procedures and standards across the Financial Crime framework
Ensure the framework is embedded operationally by supporting with the performance of thematic reviews, deep dives and assurance testing on the compliance monitoring programme
Gather and assess information for input into reporting on the outputs of the agreed monitoring programme to senior stakeholders
To develop and maintain excellent working relationships with client departments
To gather information for input into the MLRO reporting for all relevant entities within the Capital International Group Limited group of companies where required
Conduct Horizon Scanning where appropriate, supporting with Gap Analysis where regulatory outputs require and provide reports in this regard to senior stakeholders
Ensure any changes to regulatory requirements are understood, communicated and impact assessed within the required timetable
To gather information, as required, to assist with the preparation and maintenance of Capital International’s Jurisdictional lists
Provide the correct and technical and commercial interpretation of regulatory requirements as they relate to, and should be applied across, the business activities of Group
Provide regulatory support, guidance and information to entity Boards as required
Build strong stakeholder relationships within the entities of the Group and provide subject matter expertise to projects and operational teams as required
Support with the maintenance of relevant Regulatory Registers and any other records required by regulatory guidance / handbooks
Support the promotion of the Compliance Strategy for all relevant entities and ensure alignment with the overarching strategic, operational and financial goals
Provide support in the oversight and challenge of Customer Risk Assessments (Corporates/Trusts/Intermediaries etc) and Source of Funds and Source of Wealth assessment
Attend and actively support the business in relevant governance forums for high-risk and/or complex clients
Ensuring EDD standards are applied consistently and defensibly
Engagement and attendance at various external forums
To undertake the MLRO role in their absence when required
Support the MLRO in the review and investigation of suspicious activity reports and submit reports as a Nominated Person, where needed, to the FIU
Support the MLRO with work connected to the regulatory reporting responsibilities of Capital International in respect of financial crime
Support the MLRO with the fulfilment of any ad hoc Orders received from regulatory or law enforcement agencies in a timely manner relating to AML/CFT/CPF
Gather information, when required, in relation to requests for advice or information from Capital International senior management, the external auditors or regulatory/law enforcement bodies in relation to AML/CFT/CPF matters
Assist the MLRO with research into relevant AML/CFT/CPF regulatory developments so that these can be updated to the relevant stakeholders
Support the development and delivery of financial crime training courses to Capital International management and colleagues
Support the annual assessment of training needs and a review and update of core intranet-based training material
Maintain an understanding of the requirements of AML/CFT/CPF regulations and guidance relating to financial crime
To maintain understanding of jurisdictional risk relating to financial crime
Requirements:
The role holder must hold a recognised compliance qualification, equivalent to ICA International Diploma level, or relevant financial services qualification, or be deemed to be qualified by extensive and relevant experience in Financial Crime in the financial service sector
5+ years' experience in an FSA regulated (or equivalent) Financial Crime environment is desirable
Significant experience across all Financial Crime related disciplines within the financial service sector
Good technical knowledge of Financial Crime, Regulatory, and Legislative requirements, predominantly from an Isle of Man, UK, and EU perspective
Good knowledge of banking and investment products and processes and industry best practice, particularly in the offshore market
Experience of dealing with relevant external stakeholders, to include the Financial Intelligence Unit and the Attorney General’s office, including day to day relationships and visits
Practical experience of translating regulation into a working document understood by the business
Experience of dealing with complex structures, Trusts and High-Risk clients
Strong report writing skills
Excellent interpersonal skills and the ability to relate with all parts of the business particularly Senior Management
Ability to identify possible concerns/objections and structure communication accordingly
Ability to deliver with confidence when dealing with people at all levels, both internally and externally
Highly organised with excellent attention to detail
Resilient and pragmatic in a regulated, fast-paced environment