Client Compliance

Global Fund provider
- Internal and External Compliance
- DMLRO/AMLCO/MLRO

Job Specification:
**Technical / Regulated**
- Work with the Compliance team to ensure Apex are compliant with legal and regulatory requirements and best risk/compliance practice.
- Serve as AMLCO, MLRO & DMLRO to the allocated client entities.
- Understand the Cayman AML Regulations and ability and willingness to perform AMLCO, DMLRO and MLRO functions in line with Cayman requirements and relevant international standards, including but not limited to, FATF.
- Ability to identify and summarize any material developments in its business and other activities.
- Understand and be able to consider and advise on maintaining adequate systems to identify risks in relation to persons, countries, business relationships and activities, and to:

- conduct ongoing monitoring of business relationships or one-off transactions in accordance with the Regulations;
- conduct transaction monitoring reviews in relation to the fund
- present any updates or key findings to the Board/ Fund controlling parties
- consider and make any Suspicious Transaction Reports (STR’s)
- develop AML & CFT Policies and Procedures
- develop and prepare AML Business Risk Assessments
- perform AML & CFT sample testing and AML assurance reviews
- Monitoring the systems and controls (including, without limitation, the AML/CFT Procedures and other documented policies and procedures, in line with the requirements of the Regulations, as amended from time to time)
- Carrying out regular audit of the AML/CFT Procedures and any other policies and procedures used by, or on behalf of, the Company, to adhere to the requirements of the Regulations;
- Maintaining logs, as determined to be necessary, with respect to declined business, politically exposed persons (as such term is defined in the Regulations), and requests from supervisory and competent authorities, particularly in relation to investigations;
- Advising the Board of AML/CFT compliance issues and any issues with respect to the Company Compliance Functions, that require the attention of the Board;
- Reporting at least annually to the Board on the maintenance of the Company Compliance Functions and the Company's compliance with, or compliance on behalf of the Company with (as the case may be), the AML/CFT Procedures; and
- Acting as the main point of contact with the supervisory and other competent authorities in the Cayman Islands in relation to AML/CFT and responding promptly to requests for information.
- Filing a SAR with the FRA in accordance with the Regulations, if deemed appropriate;
- Maintaining a log of all reports of Suspicious Activity (including where the filing of a SAR is not deemed necessary or appropriate);
- Keeping the Board informed of all internal reports of Suspicious Activity and SARs filed with the FRA, to the extent permitted by legislation and regulation;
- Providing assistance as a point of contact for CIMA, and other regulators and law enforcement as applicable and necessary under the applicable legislation and regulation;
- Functioning as the point of contact with CIMA for the purpose of the Regulations; and
- Be able to perform the role of the DMLRO, in discharging the functions of the MLRO, pursuant to the MLRO Services, in the absence of the MLRO.
- Embedding a compliance culture within Apex and through personal engagement with client entity governing bodies / committees.
- Driving forward the development, implementation and embedding of SAR, AML/CFT and associated regulatory policies and procedures, including robust control procedures.
- Responsibility for the client entity screening process and various Compliance registers and reviews (including assisting with new business).
- Assisting with the regulatory aspects of client entity audits.
- Conducting ad hoc reviews and/or special investigations as required.

People
- Contributing in regular 1:1s, appraisals and development meetings.
- Providing support and direction and sharing examples of best practice with relevant business areas and colleagues.

Skills Required:

- Strong academic background and industry relevant professional qualification.
- In depth knowledge of the Finance industry
- Excellent people management, interpersonal (at all levels), analytic, and diplomacy skills.
- Strong organisational and time management skills, with the ability to meet deadlines in a fast-paced environment.
- A good level of commercial and fiduciary risk awareness.
- Sound working knowledge of statutory requirements and financial services legislation, together with relevant guidance notes and Codes of Practice.
- Ability to communicate complex and potentially sensitive issues to client entities / across the business.
- Discretion / ability to handle confidential information.