Compliance Office and Mlro

JOB DESCRIPTION - MLRO AND COMPLIANCE OFFICER

**Functions and objectives**

**Regulation**

Money Laundering Reporting and Compliance Officer with SM16/17 approval. Contact point with enforcement agencies including NCA. Responsibility for ensuring a system is in place capable of detecting ML. Submission of suspicion reports. Monitoring changes in UK and Head Office policy. AML Training

Responsibility for ensuring we have procedures capable of detecting and preventing violations of international sanctions. Monitoring changes in UK, international and Head Office policy.

Also, provide advice (without formal signatory powers) on:

- PRA and FCA (but not submission of statistical returns)
- Information Commissioner (for the Data Protection Act)
- Bank of England (but not submission of statistical returns)
- UK Finance and Association of Foreign Banks
- Bribery Act
- Banque Banorient France compliance department
- FATCA contact point (but not Responsible Officer)

Monitoring changes in policy in the areas set down above and advising senior management of any implications.

Ownership of the bank’s account opening forms and Terms and Conditions (although not for Facility Letters). Provide support and advice on a best efforts basis on any area of banking law or practice, with a view to minimising expenditure on legal advice.

**MLRO Responsibilities**

1. Annual review of Risk & Control Framework to identify new threats and potential impact to the business, implementing appropriate controls and procedures to mitigate the risks. The risk assessment includes the Bank’s exposure to money laundering and terrorism finance.

2. Lead the Bank's implementation of AML, anti-bribery and corruption policies and procedures.

3. Ensure the Bank has in place effective systems, procedures and controls to detect money laundering and financial crime and that these are tested quarterly with breaches and remedial actions reported to senior management and head office.

4. Ensure the Bank’s manual and automated screening rules for PEP and sanctions align with those set by head office and maintain up to date screening lists to comply with UN, EU, UK and US sanctions.

5. Ensure staff are trained to discharge satisfactorily their responsibilities in combating money laundering, terrorism finance and fraud.

6. Provide independent sign-off for on-boarding and continuation of customer relationships, including PEPs.

7. Ensure customers are classified correctly for AML risk and on the correct account review cycle, in particular, the higher risk customers are reviewed at least annually. All customers are to be reviewed at trigger event.

8. Review and sign off the Bank's account opening terms and conditions, keeping them current with legislative and regulatory requirements.

9. Point of contact for law enforcement agencies, assisting with investigations, and compliance with production and freezing orders.

10. Act as Nominated Officer ensuring the Bank meets its legal obligations in reporting suspicious account activity to the National Crime Agency. Review and sign-off submissions for quality control.

11. Provide guidance to senior management and staff on AML best practice, with reference to FCA handbook and JMLSG.

12. Keep up to date with changes to legislation and regulatory requirements related to money laundering and financial crime through review of publications by regulatory bodies and by attending networking groups and training in the industry.

13. Ownership of the Bank's register of PEPs. Submit monthly analysis of transactions to head office in accordance with our PEP reporting guidelines.

14. Undertake annual MLRO report to senior management and head office. The MLRO annual report should highlight changes to legislation and regulations, comment on new and current money laundering risks, highlight learning from breaches (including those published by the FCA), including fraud incidents. The report should also recommend any improvements to systems, procedures and controls.

15. Submission of regulatory reports including the annual financial crime report to the FCA.

16. Inform the FCA of any significant issues.

17. Point of contact for BANQUE BANORIENT FRANCE Bank France SAL Data Protection Officer based in head office. Implement and ensure compliance with policies and procedures on GDPR.

20. Ownership of data breach reporting to senior management, and if appropriate, undertake onward reporting to the ICO.

21. Review publications/notifications and attend seminars and workshops to keep up to date with legislation and regulatory requirements on data protection.

**Permanent Controller Responsibilities**

1. Ensure documented regulatory and compliance policies and procedures are in place, and where appropriate, they align with group policies and procedures, they are clearly articulated, and are up to date with all legislative and regulatory requirements.

2. Monitor and test quarterly key controls to ensure they remain relev