Working in partnership to build better businesses.
Triton is an investment firm that believes in engaging with boards, managers and employees to build better businesses. We are entrepreneurs who invest capital where we can see an opportunity to create long-term value.
We believe Triton is a great place to work and we want our team to be entrepreneurial, enjoy being part of a collective effort, inspire and challenge each other, and to bring an international mindset.
The Conducting Officer for Compliance, AML and Complaints Handling (CO) will have particular focus and responsibility for:
- Promotion of a robust Compliance and AML culture in the AIFM which will require the CO to be the “Responsible du controle du respect des obligations” (RC) for TIMS and all AIFs managed by the AIFM and the Complaints Handling Officer.
- Assess appropriateness of Compliance and AML policies and procedures to ensure they correctly reflect current law and industry practice in Luxembourg
- Providing strategic leadership and guidance to the Conducting Officers, AIFM Board and Funds on the regulatory implications of business developments as well as to the wider Triton stakeholders
Regulatory watch
- Working alongside the Triton Regulatory Horizon Team to ensure that the AIFM remains up to date on all relevant regulation and identifying all regulatory updates potentially affecting the AIFM and its managed AIFs and escalating for review to the Conducting Officers Committee and AIFM board, where relevant
- Working with the Triton Compliance and Legal teams to enable implementation of the applicable laws and regulations
- Working with legal counsel to ensure all Compliance related procedures and policies are updated and maintained according to regulatory changes
- Assisting with the identification of any process weaknesses and raise associated mitigation actions, where required
- Where relevant, arrange relevant trainings on regulatory updates
Activity monitoring
- Compliance Monitoring Programme (CMP) and activities monitored within that CMP, including identification and assessment of compliance risks, so that all relevant testing is carried out, and where necessary corrective measures are implemented
- AML/KYC on UBOs of target Portfolio Companies in closing process to assist with completion of AML on the Asset
- Assisting with the validation of structure and ownership charts and AML reliance letters, where relevant
- Training new joiners and existing staff on their ongoing Compliance obligations
Monitoring of delegates and branches
- To assist the AIFM Conducting Officers with Compliance and AML due diligence, both initial and ongoing, on the AIFM service providers/delegates
- Assisting and participating in the implementation of the regulatory compliance controls on the delegated functions
- Managing the Compliance and AML obligations of the branches including reporting to the relevant local regulators and annual onsite visits
Reporting
- Creating and sending periodic compliance reports to the Conducting Officers, Board(s) and the CSSF regarding the ongoing Compliance and AML activities
- Working with the other Conducting Officers on the various thematic reviews and other regulatory questionnaires issued by the CSSF
- Assisting in the investigation and reporting of any suspicious activities/transactions
Management of the AML on the Management Incentive Programmes (MIP)
- MIPs provide the senior managers and directors of portfolio companies with co-investment interests in their own company. The Triton fund owning the portfolio company is aiming to sell the company in the future for a profit. A percentage of that profit will be distributed to the MIP programme.
- This role will include oversight on the performance of ongoing AML/KYC compliance reviews in respect of the MIPs, including the screening of UBOs and PEPs that sit within MIP Companies
The Candidate Profile
In terms of the experience and personal competencies required for the position, we would highlight the following:
Essential Requirements
- Bachelor’s degree or Master’s degree, in Law, Accounting or Finance
- A strong understanding of the relevant Luxembourg regulations and knowledge of the AML/CFT regulations in relation to an AIFM and private companies
- At least 7 years’ experience in terms of funds and compliance background, preferably in alternative asset management and with experience of a Luxembourg AIFM or ManCo. UK and/or Channel Island experience is beneficial.
- Experience in managing regulatory dialogue and responding to a regulator’s inquiries
- Experience in regulatory review and interpretation of regulations as applicable to the business
- Prior experience of supporting large change projects
- Fluency in English (written and spoken), other European languages a plus
Personal Attributes
- A proactive and positive, highly motivated, collaborative team player
- Strong business judgement and willingness to build working relationships across Triton to enhance collaboration
- A “people person” with a calm and tactful manner and flexible attitude
- Good attention to detail and ability to handle confidential information appropriately
- Resilience, integrity and the ability to consider whether action is necessary or unnecessary before proceeding
Triton is an equal opportunity employer. We recognise that diversity is key to our continued success, and strive to maintain a fair and equitable recruitment process for all applicants.
