BNY Mellon Careers
Head of Compliance
The role reports into the Chief Compliance Officer, with responsibility for:
- Establishing and managing the provision of advisory, monitoring and regulatory training services;
- Advice to internal clients and meeting with external clients to explain about Pershing’s services;
- Oversight of the regulatory reporting for Pershing (Channel Islands) Limited (PCI)
- Fulfilling the role of the Money Laundering Reporting Officer and Money Laundering Compliance Officer for PCI, as well as the Data Protection Officer;
- Acting as a Principal Person under The Financial Services (Jersey) Law 1998 and;
- Attending relevant Board and/or Committees.
- Strategic and Corporate Responsibilities
- To participate in the development and implementation of the business strategy in Jersey within specific remit of areas of responsibility;
- To ensure the firm meets with the corporate requirements of the group as well as the strategic requirements of the Bank of New York Mellon within the specific remit for areas of responsibility;
- To ensure that the management of the firm is kept fully informed of departmental strategy and other corporate issues;
- To participate as a member of the boards and committees outlined in Table 1;
- To ensure that the areas of responsibility of the role are running efficiently and effectively and in a controlled manner, including reflecting appropriate apportionment of responsibilities, segregation of duties and controls to prevent conflicts of interest;
- To ensure that there is appropriate and adequate management information to facilitate a review of the key performance and risk indicators at senior management level;
- To ensure that appropriate policies are developed across the firm to meet regulatory and control requirements, and to delegate responsibility for implementation of policies and the development of procedures to the directors and other managers of the firm, where required;
- To confirm that the Business Continuity and Disaster Recovery arrangements for all areas under the responsibility of this role are maintained up to date.
- In conjunction with the Pershing EMEA Regulatory Change team, monitor regulatory change and prepare impact analyses of any relevant Jersey consultation documents. This will involve providing guidance on the implications of such changes and assistance in the implementation of any necessary developments across Pershing Europe;
- Maintaining involvement in the local regulatory arena to promote the interests of Pershing’s business model;
- Providing advice and responding to queries on regulatory and compliance issues arising, and applying the rules to business and operational current and developing models;
- Participating in projects including identifying, handling and resolving compliance issues relating to business development;
- Managing the regulatory relationships in Jersey including proactive liaison with and answering queries from Regulatory Authorities and Exchanges as required (and law enforcement agencies if appropriate);
- Identifying enhancements to in-house compliance procedures to confirm PCI’s on-going compliance with regulatory requirements as required;
- Establishing complaints handling systems and recording and responding to complaints;
- Handling applications for firm and individual regulatory registrations, as required;
- Interacting with both the Internal Audit Department and external auditors, in conjunction with the Jersey Country Manager, as required to present correctly the activities of PCI both internally and to any external reviewer;
- Maintaining the PCI Compliance Manual;
- Approving PA dealing requests for all persons covered by the PA Dealing Rules; and
- Production of the monthly compliance report and regular reports to the Oversight Committee and the Board of PCI.
- Liaison with the Compliance Monitoring team based in Liverpool to ensure the adherence of PCI to the relevant rules and policies. This involves both monitoring oversight of the functions which are outsourced from PCI to , Liverpool or Chennai as well as monitoring of the local PCI entity;
- Identifying any enhancements or further developments required to the rolling compliance monitoring programme, Global Compliance Monitoring System (“ GCMS”), to confirm compliance with the JFSC and other rules where appropriate, which contribute to the firm’s annual compliance review;
- Co-ordinating the overall PCI monitoring programme with the PSL Compliance Monitoring Team and producing standardised reports identifying issues arising;
- Discussing rectification processes with business units, and ensuring that improvements are implemented as required;
- Undertaking ad-hoc reviews and investigations, in addition to those scheduled by GCMS, as are identified as necessary to confirm PCI’s processes operate in accordance with regulatory requirements; and
- Maintaining the PCI Breaches Log and monitoring any Operational Risk events arising for the location which may have a compliance implication for PCI.
- Provision of training programmes as required by the JFSC in the location and as required by Pershing both locally and to staff elsewhere on Jersey regulatory requirements; and
- Developing and updating of compliance training programmes, in conjunction with other members of the Compliance Department, and delivery of such courses as required.
- Anti-Money Laundering
- Developing necessary controls, policies, procedures, training and education and maintaining policies in line with (i) statutory and regulatory obligations (ii) Bank of New York Mellon policies and (iii) advice from law enforcement agencies;
- Receiving internal reports, undertaking internal review of all suspicions and determining if such suspicions require disclosure to law enforcement, regulatory agencies or Bank of New York Mellon
- In conjunction with Pershing EMEA Compliance, approve new clients through due diligence procedures including on-site visits and review of KYC and AML documentation and procedures;
- In conjunction with Pershing Europe Compliance, ongoing review of existing clients through the performance of regular reviews of KYC documentation, annual AML certificates, analysis of incident reports & regulatory enquiries and client visits based on risk rankings;
- Be the point of contact with Jersey clients with respect to AML and fraud issues;
- Fraud investigations in co-ordination with other Pershing Europe support functions;
- Be the point of contact for requests between PCI and the law enforcement or regulatory agencies; including representing PLC to all external agencies (regulators, national authorities and law enforcement agencies) and in any other third party enquiries relating to financial crime; and
- In liaison with the FCT undertake transaction monitoring as required .
- Data Protection
- Acting as Data Protection Officer for PCI and ensuring the necessary regulatory permissions are maintained and that Data Access Requests and Freedom of Information Requests are processed.
- Regulatory Reporting Oversight
- Overseeing and reviewing of all regulatory reporting statements prepared for PCI including, the reports submitted to the JFSC;
- Working with Pershing Europe’s Finance Department to implement any new regulatory reporting developments, systems and process improvement initiatives;.
- Technical/functional and operational knowledge required to run a successful Private Wealth and Custody operation in Jersey;
- Strong understanding of the industry from a tax, regulatory and operational perspective;
- Understanding of the fundamentals of workflow, operational and systems design;
- Strong track record in leadership and management of a Private Wealth business; and
- Understanding of UK and Jersey regulatory requirements.
Required Technical Knowledge
- An understanding of the industry from a regulatory perspective and a general awareness of company legislation and UK regulatory requirements;
- Detailed knowledge of the rules and regulations of the JFSC or equivalent regulation as well as up to date knowledge of market practices and Exchange rules;
- Significant knowledge and understanding of legislation on money laundering, together with the Handbook for the Prevention and detection of Money Laundering and the Financing of Terrorism;
- Previous experience in Wealth Management or Investment Banking Compliance with a knowledge of the Client Money and Asset rules;
- Technical/functional knowledge as required for the role.
- Maintaining detailed working knowledge of the JFSC rules and regulations and other relevant market practices and rules and co-ordination of all regulatory examinations of PCI;
- To undertake the role the job holder will be registered with the JFSC as a principal person; and
- To uphold the JFSC’s Code of Practice for Investment Business and the JFSC’s Orders as applicable to Pershing’s business and to actively encourage a culture of compliance throughout the firm.
- Contribute to the effective governance within Pershing EMEA
- Play an active role in local committees and local boards, offering constructive challenge and helping to support the Committee/Board fulfil its role and responsibilities for those they are a member. Where the job holder acts as a Chair of a Board/Committee, ensure the Board/Committee is effective in all aspects of its role, facilitate and encourage informed and constructive debate on key issues and ensure that members receive relevant management information in an accurate, timely and clear form.
- Build a good understanding of the EMEA governance framework, including escalation requirements
Generic Staff Responsibilities
- Comply with all BNY Mellon and Pershing corporate policies and procedures, including HR policies and procedures, applicable to Pershing.
- Alert management immediately of any significant changes to business risks and internal control effectiveness.
- Notify management and/or the Chief Compliance Officer immediately on discovery of any material regulatory breach.
- Comply with all Security and Health & Safety policies and procedures operating within the business.
BNY Mellon is an Equal Employment Opportunity Employer.
Primary Location: Jersey-Jersey-St Helier
Internal Jobcode: 85162
Organization: Pershing International-HR16947
Requisition Number: 1907535