Head of Compliance, UK and MLRO
Summary
The Head of Compliance, UK for Kepler Capital Markets (KCM) London branch holds the UK Financial Conduct Authority (FCA) controlled function of CF10, Compliance Oversight and CF11, Money Laundering Reporting Officer for Cheuvreux International Ltd (a group company of KCM). They are responsible for the day to day management of all compliance within the London branch, and will have a reporting line to the Head of Compliance in Paris to enable coordination of compliance policies. The role will involve developing compliance activities across all areas of the business, and coordinating these within the framework of the overall Kepler Capital Markets Group compliance strategies. The Compliance Manager shall act as the primary compliance contact for that business, and is therefore required to establish a strong relationship with the business and also the UK regulators and Exchanges. They must maintain an appropriate knowledge of KCM’s business, including the products offered, the services provided to clients and the processes and systems and controls. They will maintain an awareness of the current regulatory environment in the UK, including a working knowledge of the applicable laws, rules and regulations and other requirements of the FCA, London Stock Exchange and other relevant regulatory bodies. They will monitor developments in local and international legislation and regulations and analyse applicability to KCM’s business in UK, where necessary preparing recommended courses of action, and advising management on the implications of any new rules and regulations. The Head of Compliance, UK will work with all business areas to identify legal and regulatory issues that affect their operation and deal with such issues in a proactive and commercially minded manner.
Key Responsibilities
- Compliance Policies and Procedures
To ensure that there are adequate, clear and sufficiently detailed compliance and Financial Security policies and procedures in place for KCM so that relevant Exchange requirements, regulations, rules and Head Office requirements are properly disseminated. On an ongoing basis, ensure that new laws, regulations and best market practices that will impact on these policies and procedures are identified such that the documents can be updated as appropriate. To assist in developing policies and procedures for other designated business units. Review and comment on draft policies and procedures produced by KCM Group Compliance in Paris, ensuring that where appropriate these are implemented locally.
- Regulatory Advice and Queries
To provide effective and co-ordinated compliance advice in a timely manner to KCM management and staff, as well as ensuring an appropriate and timely two way flow of information between Compliance and the business. Compliance advice will include consideration of best practice, the regulatory requirements of competent authorities, as well as compliance with internal procedures and directives (eg FIDES and London procedures). In respect of inquiries from Regulators or Exchanges, to work with the relevant functions (such as Operations, Legal, etc) to ensure an accurate and considered response within the required deadline. Develop and maintain a relationship with management and other relevant employees to ensure that early advice is sought on proposed transactions and operating practices. Maintain constructive working relationships with all regulatory authorities, in particular the FCA and London Stock Exchange.
- Training and Awareness
To develop, organise and deliver regular induction, business specific compliance and Financial Security training, targeted themed training and general awareness campaigns (in conjunction with the Central Compliance team), so as to maintain awareness by the KCM staff of applicable rules, regulations and best practice. A yearly review of training needs is to be undertaken and a training and awareness programme for KCM established and agreed with the Head of Compliance. All training is to be accompanies with full records.
- Compliance Monitoring Programme
To develop and implement a comprehensive risk and rules based Compliance Monitoring Programme for KCM covering routine compliance monitoring of various aspects of the business, as well as rolling Business Reviews, reporting on identified weaknesses and following through to ensure implementation of agreed action points. Potential compliance issues are to be identified and addressed in a timely manner. Conduct internal investigations with respect to actual or potential irregularities, compliance breaches and violations, reporting the findings and recommendations to KCM Head of Compliance, KCM Group Compliance (Paris) and Management as required. Work with external and internal audit to identify key regulatory and compliance matters that should be included in the audit programme. Maintain awareness of compliance issues raised by internal and external auditors, Legal, Financial Security and regulatory bodies and coordinate with Management to ensure that appropriate steps are taken to resolve such issues.
- Rolling Business Reviews
To plan and participate in regular risk based business reviews across all areas of KCM, reporting on identified weaknesses and following through to ensure implementation of agreed action points.
- Trade Monitoring and Exchange Business
Where appropriate to coordinate responses to issues raised by the FCA, other regulators, exchanges or multilateral trading facilities, ensuring that trades are reviewed and investigated as required.
- APER and Exchange Registration
To ensure that individuals working for KCM have the appropriate FCA registration prior to undertaking investment business or carrying out their role. Advise on and process FCA approvals and withdrawals of staff as Approved Persons performing certain controlled functions and/or Significant Management Functions, maintaining a database of all FCA Approved Persons.
- Management Reporting
To develop accurate and meaningful monthly Management Information and ensure that it is delivered on time for routine Compliance reports. Provide periodic compliance reports to KCM management and the Head of Compliance.
- Relationship with Head Office
To foster the relationship between KCM London branch and Head Office, ensuring that where possible there is consistent application of compliance standards that Head Office is aware of relevant cross border business, and that cross border issues are escalated where appropriate. Report on a periodic basis, as appropriate, to Head of Compliance, Head of Anti-Money Laundering, Senior Management and the Group Compliance Department (Paris).
- New Client Approval Process
To advise on the requirements for the acceptance of potential new clients and supporting documentation required. Refer to and consult with the Group Compliance team / Group Anti-Money Laundering team on higher risk clients and any client requiring additional approval by Financial Security. Review and approve all new Client Files (KYC Form plus regulatory and anti-money laundering due diligence documentation) to ensure compliance with UK regulations and internal procedures.
- Ad hoc
To assist the Head of Compliance and senior management with ad-hoc tasks and projects that may be assigned from time to time. The Compliance Manager for KCM is also required to represent Compliance on internal and external committees and steering groups from time to time, as agreed with the Head of Compliance.
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