Job Description

Synopsis of Role

This is a standalone role based in Jersey with no staff management responsibilities.  The Jersey office is a team of 4 and there is an expectation that the role holder will provide support to the Jersey team as required. The individual will work closely with the UK based Compliance function and the Head of Compliance for Ireland.  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.

Key Responsibilities

1. Strategic and Corporate Responsibilities
   • To participate in the development and implementation of the business strategy in Jersey and EMEA within specific remit of areas of responsibility;
   • To ensure the firm meets with the local and 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, and additional EMEA committee memberships as appropriate;
2. Control Environment and Operational Responsibilities
   • 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 and ownership and resolution of any issues arising and, where appropriate, escalation to senior management as required;
   • 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.
   • Advisory
     • 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 EMEA;
     • 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 for Pershing Channel Islands, and applying the relevant rules to business as they relate to  current and developing operational models;
     • Participating in Compliance and business led 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 Jersey client 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 other committees as required from time to time) and the Board of PCI.
   • Compliance Testing
     • Liaison with the Compliance Testing team based in Liverpool to ensure the adherence of PCI to the relevant rules and policies.  This involves both testing 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, the Global Compliance Risk Assessment Framework Tool (CRAFT), 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 testing programme with the Compliance Testing 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 CRAFT, 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.
   • Training
     • 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) local 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 local 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 the Pershing KYC Officer and utilising a risk-based approach conduct ongoing review of KYC documentation, AML certifications, analysis of incident reports and regulatory enquiries as they related to new and existing clients contracted with Jersey office using a combination of onsite and desk- based reviews
     • Be the point of contact with Jersey clients with respect to AML and fraud issues
     • Fraud investigations in co-ordination with other Pershing EMEA support functions
     • Be the point of contact for requests between PCI and the law enforcement or regulatory agencies; including representing PCI to all external agencies (regulators, national authorities and law enforcement agencies) and in any other third party enquiries relating to financial crime;
     • In liaison with the FCT undertake transaction monitoring as required; and
     • Responsible for ensuring that any local regulatory requirements not captured within Group policies or Pershing EMEA Tier II policies are documented and managed locally.
   • 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
     • Preparation of the Business Risk Assessment
   • Working with Pershing EMEA’s Finance Department to implement any new regulatory reporting developments, systems and process improvement initiatives
   • Jersey office responsibilities : Assist the Jersey office team as required from time to time with the day to day running of the office, including opening, office cover, closing, mail pick up, opening, scanning and banking etc. as required in a small team.

Required Technical Knowledge

• Technical/functional and operational knowledge of custody clearing and settlement and trade execution product and services;
• 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 Jersey Financially Regulated business of a Private Wealth business; and
• Strong, detailed knowledge and practical understanding of Jersey regulatory requirements as well as a working understanding of UK regulatory requirements. 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, Financial Advisory, Trust or Investment Banking Compliance with a knowledge of the Client Money and Asset rules;
• Technical/functional knowledge as required for the role.

Regulatory

• 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 (including MLRO, CO and MLCO); 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.

Governance Responsibilities

• 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 Pershing EMEA governance framework, including escalation requirements and follow through to completion of relevant issues raised to Committees, Boards, Councils, etc.

Generic Staff Responsibilities

• Comply with all BNY Mellon and Pershing corporate policies and procedures, including HR policies and Code of Conduct and all procedures, applicable to Pershing EMEA.
• Alert management immediately of any significant changes to business risks and internal control effectiveness and follow through to resolution.
• Notify management and/or the Chief Compliance Officer immediately on discovery of any material regulatory breach and associated remediation plan.
• Comply with all Security and Health & Safety policies and procedures operating within the business.

Shared Values and Core Competencies (required for all roles)

1. Values and Behaviours
   • Client Focus – demonstrates clear understanding of importance of effective customer service, internally and externally.
   • Trust – Evidence high standards of integrity and openness.
   • Teamwork – demonstrates ability to work effectively as a member of a team, a collaborative style, and understands the value of diversity.
   • BNYM promotes a culture of inclusion. The role holder will actively incorporate perspectives from across all  backgrounds, experience, and expertise that can help cultivate belonging.
2. Core Competencies
   • Excellent communication skills – ability to clearly articulate regulatory interpretation/requirements at all levels within the organisation
   • Developing Strategic Relationships – Using appropriate interpersonal styles and communication methods to influence and build effective relationships with business partners (e.g., peers, functional partners, external vendors, and alliance partners).
   • Change Leadership – Continuously seeking (or encouraging others to seek) opportunities for different and innovative approaches to addressing organizational problems and opportunities.
   • Client Orientation – Cultivates strategic client relationships and ensures that the client perspective is the driving force behind all value added business activities.

How to Apply

Job Types: Full-Time.

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