Deputy MLRO

  • Competitive
  • London, England, United Kingdom
  • Permanent, Full time
  • Société Générale - UK
  • 15 Oct 17 2017-10-15

Deputy MLRO

People join for the impact they can have on us. They stay for the impact we have on them. A flatter structure offers visibility and exposure beyond that of our competitors, so you know our names, and we know yours. It's personable, human, and inspires success through passion. By encouraging open mindedness and a willingness to share ideas, we have adapted to market changes and thrived through innovation. Bringing words like “hard work” and “dedication” together with “community” and “respect” has enabled us to work collaboratively and build our future together. We call this Team Spirit and it's what makes us different. It's what makes you different.


Description of the Business Line or Department

Mission Statement of GBS Compliance:
To enhance and maintain a robust compliance framework, in partnership with all stakeholders, to execute the firm's strategy in accordance with its risk appetite, regulatory expectations and industry best practices”.

In order to achieve its mission statement, GBS Compliance activities are centred around five key objectives, in support of senior management, business lines and resource functions, where the business lines have first level accountability and responsibility, and where GBS Compliance's responsibility is with respect to compliance, reputational and conduct risk matters. These five key objectives are as follows:
• Providing advice and policy development
• Facilitating knowledge and awareness
• Undertaking monitoring and surveillance activities
• Performing risk assessment, review and control activities
• Managing the relations with regulators

Summary of the key purposes of the role

The Financial Crime Unit (‘FCU') is part of the wider Compliance function. It is responsible for providing advice and guidance to business management for the SG investment banking business in London (SG London Branch, SG International Ltd, Lyxor Asset Management UK LLP and Descartes Trading SA – collectively “SG London”) on the financial crimes risks faced by their business and providing an oversight function on the effectiveness of mitigation controls and processes.

The key purposes of the role is:

• To act as a Deputy MLRO, with specific focus on the activities conducted through the following entities; SG London Branch (“SGLB”), Lyxor Asset Management UK LLP (“Lyxor”) and Descartes Trading SA (“Descartes”).

• To assist with the implementation and management of the anti-financial crime strategy within the UK covering anti-money laundering, terrorist financing, bribery and corruption and economic sanctions;

• To work with the Head of the Financial Crime Unit and other members of the team to maintain and further enhance SG London's financial crime compliance programme in line with SG Group Instructions relating to financial crime matters and UK legal and regulatory standards;

• To deputise, in the absence of the Head of the Financial Crime Unit, in fulfilling the responsibilities of the MLRO;

• To manage the day to day workload of the staff within the Unit who have responsibility for coverage of SGLB, Lyxor and Descartes, ensuring that this is undertaken in a manner that is risk focussed and with appropriate prioritisation. To act as their line manager.

Summary of responsibilities

To take responsibility for, or assist the Head of the Financial Crime Unit, in the following:

o Ensuring that AML and KYC policies comply with UK requirements within SGCIB UK and liaising with SGUK AML functions to ensure consistency. In addition, to liaise with the SG Group Compliance function in Paris in respect of these policies;

o Developing, implementing and managing the anti-money laundering strategy within the UK covering anti-money laundering, terrorist financing, bribery and corruption. To liaise with SG Group Compliance in Paris in respect of that strategy;

o Advising local and Group management on complex anti-money laundering issues;

o Providing advice, direction and training to the KYC function and approving high risk accounts referred by the KYC team to the FCU;

o Developing and maintaining appropriate monitoring controls of the KYC function;

o Overseeing and, where appropriate, undertaking, the internal investigation of issues arising and suspicious activity referrals which may have money laundering implications.

o Overseeing the processes associated with AML investigations, including the investigations action plan, follow-up of recommendations arising from investigations, and maintaining an up to date log of the status of investigations

o Submitting reports to NCA and FCA, as required, and management of the follow-up process, to ensure that the responses from such external agencies is appropriately applied, maintaining all associated records in accordance with legal and regulatory requirements

o Developing, implementing and overseeing review programmes, including the monitoring and surveillance of AML within SGCIB UK, ensuring timely identification of risks and the development of cost- effective and efficient counter-measures

o Ensuring AML, embargoes and sanctions, and bribery and corruption considerations are appropriately considered as part of the new Product Committee process, and influencing the approval or otherwise of new products from an AML perspective;

o Implementing and maintaining appropriate management information for AML; including the completion of an annual report to senior management on the operation and effectiveness of the SGCIB UK's AML systems and controls;

o Advising management on the planning, review and design of sanction/embargoes and anti-bribery and corruption (“ABC”) controls;

o Developing and overseeing relevant training.

o Maintaining a detailed working knowledge of the FCA rules and regulations, and UK AML, ABC and embargo and sanctions related legislation, and a broad awareness of AMF, ACPR and other regulatory and exchange rules and regulations as required

o Identifying training and development needs of assigned staff, and ensuring that such staff provide feedback from the required training courses, once attended

o Proposing and contributing to the promotional and remuneration prospects of Central Compliance Staff, with input to the assessments of other Compliance staff

o Contributing to the development of the annual department strategy and Compliance Plan

o Uphold the 11 FCA Principles for Business and the 7 Statements of Principle for Senior Managers in order to promote a culture of compliance and treating customers fairly within SGCIB UK

o Actively promote the business principles both within, and externally to, the Compliance Department

o Maintain proactive interaction with SAFE Department.

o Attendance at forums of, and participation in, initiatives driven forward by, trade associations and other industry bodies, ensuring that SG's views on regulatory developments which could impact on its business in the UK are provided as part of any consultation initiatives and that relevant benchmarking is undertaken and played back within Société Générale as appropriate.

o Management of the proactive participation in the maintenance of the risk cartography, ensuring that the inherent regulatory risks posed by business activity are determined, the mitigating factors assessed to determine the residual risk and the actions required to further mitigate, or reduce, the regulatory risk

Level of Autonomy and Authority

Role involves acting with initiative and autonomy, where appropriate, ensuring proactive upward reporting of relevant issues, as well as seeking guidance and advice as required


Profile:

Competencies

• Operational Skills

• Regulatory Skills

• Communication Skills

• Flexibility- Adaptability

• Ability to make decisions

• Ability to Work Under Pressure

• Analytical Skills

• Initiative

• Leadership Qualities

• Teamwork

• In-depth working knowledge of FCA and other regulatory rules

• In-depth working knowledge of financial crime related legislation

• Knowledge of EU directives relating to financial services, as well as broad knowledge of AMF and ACPR rules

• Compliance experience relating to Financial Crime

If you feel you have the required experience and qualifications, then please apply to the SG Resourcing Team, and we will manage your application. At Societe Generale, we believe our people are our strength and are core to the success of our business. As such, we search for, recruit and appoint the best available person on the basis of aptitude and ability, regardless of sex, marital or civil partnership status, race, colour, nationality, ethnic or national origins, pregnancy, disability, age, sexual orientation, religion, belief or gender reassignment.