Group Head of Financial Crime

**Location: Gloucester - Hybrid**

**Salary: Competitive with excellent benefits, company bonus and hybrid working**

**Duration**:Permanent**

**Hours: 35 hours per week, Monday to Friday**

**Role purpose**:
Responsible for Financial Crime (MLRO) activity across all UK Group functions and UK and Ireland Group SBU’s.

Holds the regulatory senior management accountability SMF17 for relevant regulated entities within the Group and be accountable as the MLRO for the Group Functions, with responsibility for implementation of the firms financial crime policies and procedures and ensures that appropriate monitoring processes and procedures across the Group are established and maintained.

**Key accountabilities**:

- Define and lead the implementation of the Group’s financial crime strategy
- Act as primary point of reference for Group wide high risk referrals, including undertaking appropriate risk based assessments and holding accountability for the outcome / decisions on way forward.
- Receive suspicious activity reports from the business and ensure appropriate/timely submissions of reports to the NCA or law enforcement as required.
- Act as the primary point of reference for and represent the Group on financial crime matters to the regulatory authorities, law enforcement and relevant external bodies.
- Create and maintain Group-wide policies, standards and procedures relating to financial crime.
- Advise the Group on current and changing laws and regulations relating to financial crime and identify all policy and procedural changes required as a consequence.
- Conduct and lead financial crime themed risk assessments and perform gap analysis against rules and guidance issued by the Financial Conduct Authority, JMLSG and other relevant authorities, to identify potential gaps and exposures and ensure appropriate remedial action is taken to address identified weaknesses and exposures.
- Provide appropriate reporting (at least quarterly and annual) to the Group and SBU Boards and ongoing assurance as to the efficacy of financial crime controls and exposures.
- Provide support to Group Compliance monitoring and assist Internal Audit and Group Risk with audits and reviews covering financial crime related controls.
- Prepare and deliver training to maintain awareness of the risks and controls relevant to financial crime across the group and appropriate to the role and level of all staff and contractors.
- Investigate or provide support for investigations into financial crime control breaches and risk events ensuring appropriate communications and actions flow from lessons learned.
- Establish and maintain transaction monitoring routines, and exercise oversight across all business lines and distribution channels to ensure appropriate diligence is undertaken in new business and supply chain relationships and in ongoing higher-risk business relationships.
- Oversee the gifts and hospitality process ensuring compliance with regulation and Group standards and guidance.
- Review conflicts of interest on notification and annually, to ensure these conflicts are appropriately managed and necessary mitigating controls are in place.
- Lead and motivate a team of financial crime professionals, support their individual and collective development and to enable an appropriately resourced, specialist and professional capability for the Group
- Input to the strategic direction and development of the Group financial crime function

**Key performance indicators**:

- Ensure any sanctions issues are identified and appropriate action taken in a timely manner
- Ensure Suspicious Activity Reports are completed and conducted effectively when appropriate
- Report to GMB/GRC and other SBU Risk Boards on financial crime and risk events
- Production of an annual financial crime / MLRO report for the Board
- Positive feedback from senior management on financial crime advice and data protection advice and support received.
- Relevant Policies and Standards are maintained and communicated / available to all staff.

**Knowledge skills and experience**:

- Proven experience in compliance and management of financial crime risks including money laundering, bribery & corruption, conflicts of interest, fraud, personal account dealing / insider dealing, sanctions and politically exposed persons.
- Relevant qualifications held
- Evidence of interpreting legislation and translating this into practical actions for the business.
- Evidence of being able to develop effective partnerships with the business, ability to drive awareness and gain early involvement in project initiatives throughout the business.
- Highly effective verbal and written communication.
- Influencing and stakeholder engagement skills.
- Demonstrates sound judgement and ability to produce considered recommendations.
- Effective planning and prioritisation - balances multiple deliverables to agreed quality standards / SLA’s
- Held SMF17 position is preferable but not essential.

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