What’s the role?
The role holder will act as the appointed Money Laundering Reporting Officer (MLRO) for licensed client entities serviced by the Client Compliance team. This position ensures that client entities meet all regulatory obligations under the GFSC framework, including financial crime requirements and compliance with applicable laws, rules, and codes of practice. The individual will provide assurance to Boards of client entities, oversee compliance monitoring, and act as the primary point of contact for regulatory and law enforcement matters relating to these prescribed roles.
What you’ll be doing
Key Responsibilities
- Serve as the appointed Money Laundering Reporting Officer (MLRO) for client entities, with responsibility for receiving, evaluating, and determining the appropriate outcome of internal suspicious activity disclosures made by staff under the Proceeds of Crime (Bailiwick of Guernsey) Law, 2002 (as amended) and the Drug Trafficking (Bailiwick of Guernsey) Law, 2000 (as amended).
- Determine whether internal disclosures received from staff meet the threshold for onward reporting to the Guernsey Financial Intelligence Service (FIS) as a Suspicious Activity Report (SAR), and submit external SARs to the FIS where required, including seeking consent where appropriate.
- Maintain a register of all internal disclosures received, documenting the rationale for decisions made on whether or not to submit an external SAR to the FIS, in accordance with record-keeping requirements under the AML/CFT/CPF Handbook.
- Ensure that tipping-off obligations are observed at all times, including ensuring that staff are aware of the prohibition on disclosing to a customer or third party that a disclosure has been made or that an investigation is underway.
- Liaise with law enforcement, the FIS, and other competent authorities in connection with disclosures or investigations, ensuring that all communications are handled appropriately and in compliance with legal obligations.
- Provide guidance and support to staff on the identification and reporting of suspicious activity, acting as the escalation point for queries relating to potential money laundering, terrorist financing, or proliferation financing.
- Ensure that requests for consent to proceed with a transaction or business relationship, where a SAR has been submitted to the FIS, are managed in accordance with the applicable moratorium period and that appropriate records are maintained.
- Report to the Board of each client entity on matters relating to the MLRO function, including volumes and outcomes of internal disclosures and any material issues arising from the disclosure handling process.
Qualifications & Experience
- Relevant compliance qualification recognised by the GFSC; examples include ICA Certificate/Diploma in Compliance, CISI compliance qualifications, or equivalent. Candidates should be able to demonstrate compliance-specific continuing professional development (CPD) in line with GFSC fitness and propriety expectations
- 5 years’ relevant finance industry experience
- 5 years’ experience within the compliance environment
Knowledge
- A detailed knowledge and understanding of the Guernsey finance industry and GFSC regulatory requirements in which we operate
- Comprehensive knowledge of Guernsey AML/CFT/CPF legislation and the GFSC Handbook for Financial Services Businesses on Countering Financial Crime and Terrorist Financing (AML/CFT/CPF Handbook)
- Knowledge of Guernsey sanctions legislation, including the Sanctions (Bailiwick of Guernsey) Law, 2018 (as amended) and related sanctions orders, and the application of sanctions screening obligations to client entities
- Understanding of the GFSC fitness and propriety requirements for prescribed role holders under Guernsey financial services legislation, including the Fiduciaries Law 2000 and/or the POI Law 2020
- Familiarity with the GFSC Codes of Practice applicable to fiduciaries and/or investment businesses, and the obligations imposed on Compliance Officers and Money Laundering Reporting Officers (MLROs) thereunder
- Previous experience of acting as a CO in Guernsey
- Ability to manage competing priorities and deadlines under pressure
- Previous experience of communicating with regulators
Skills & Abilities
- Persuading and influencing
- Leadership skills
- Strong communication skills
- Attention to detail
- Ability to train and educate all levels of staff
- Building and creating a sense of team spirit and loyalty
- Ability to develop policy, procedures and processes
Role Location/Hybrid Schedule
This role is based in our Guernsey office. Although the nature of most of the roles within Gen II cannot be classed as totally flexible, there is scope in some cases for a form of Agile Working. The different ways in which Agile Working can be undertaken is dependent on the demands and needs of the business, the office space available and the individual’s preferences and circumstances.
Legal statements
This role is a prescribed role under Guernsey financial services legislation, including the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. (Bailiwick of Guernsey) Law, 2000 (as amended) and/or the Protection of Investors (Bailiwick of Guernsey) Law, 2020 (as amended), as applicable to the licensed entities serviced. As Compliance Officer, you will be required to be a fit and proper person as assessed by the Guernsey Financial Services Commission (GFSC) and will be expected to maintain that status on an ongoing basis. You will be subject to the GFSC’s fitness and propriety requirements, including requirements as to competence, financial soundness, and integrity. The GFSC may take regulatory action, including the imposition of licence conditions, suspension or revocation of approval, where the holder of this prescribed role is found to have failed to meet applicable regulatory obligations. You will be required to adhere to the requirements of the Handbook for Financial Services Businesses on Countering Financial Crime and Terrorist Financing (the AML/CFT/CPF Handbook) issued by the GFSC, together with all applicable Codes of Practice, rules, and guidance issued by the GFSC from time to time.
