JOB DESCRIPTION
Senior Manager, Financial Crime Compliance
What You'll Do
Delegation of Authority
All the powers of the Schroders plc Board (the “Board”) to manage the business of the Company and its subsidiaries (the “Group”) are delegated to the Group Chief Executive except for matters which the Board reserves to itself or delegates to others, including Board Committees.
The Group Chief Executive has delegated responsibility for Financial Crime Compliance to the Group Head of Financial Crime Compliance, through the Chief Risk Officer. The Group Head has further delegated specific responsibilities outlined in this job description to the Senior Manager/SMF17 of Financial Crime Compliance.
The role incorporates responsibility for promoting an appropriate culture and operating a suitable business model within Financial Crime Compliance having regard to the Financial Conduct Authority’s (“FCA”) objectives. This includes taking reasonable steps to ensure that conduct risks within the Financial Crime Compliance function are identified, monitored and mitigated to the standards expected at Schroders, and taking reasonable steps to ensure that the strategy for doing business in Financial Crime Compliance is sound and consistent with the interests of consumers and the integrity of the UK financial system.
The Financial Crime Compliance Senior Manager’s principal responsibilities are:
- Leading, in conjunction with the Group Head of Financial Crime Compliance, the process for identifying, interpreting, and reporting on legal & regulatory change in respect of financial crime.
- Assisting the Group Head of Financial Crime Compliance in developing, enhancing and communicating the Group's standards and frameworks for mitigating financial crime risks and overseeing and challenging of business management and local MLROs in the implementation of these Group's standards.
- Supporting, and where necessary, leading the annual Group-wide financial crime risk assessments and MLRO reports.
- Making expert judgements and decisions/recommendations on appropriate actions in relation to financial crime issues, in a time critical and risk-based environment.
- Acting as a focal point for expert advice and guidance on the application of financial crime policy and best practice, as well being a trusted advisor to the businesses within Schroders.
- Developing and delivering relevant education and training for the business and other areas of Compliance to mitigate financial crime risk.
- Managing the Group/UK Financial Crime Advisory Team and ensuring an effective and efficient service is delivered to stakeholders within the business.
- Attending appropriate industry groups to keep abreast of current or prospective regulatory developments and industry best practices and, where necessary, articulate our views.
The Senior Manager, Financial Crime Compliance also has responsibilities to the Committees they sit on within the Groups functional model
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Discharge Of Responsibilities
The Senior Manager, Financial Crime Compliance shall ensure that all their responsibilities are performed to the highest levels of integrity, quality and transparency and in a manner most likely to promote the success of the Group, taking into account the interests of key stakeholders including clients, employees, regulators, suppliers and society as a whole.
In Discharging Their Principal Responsibilities, The Senior Manager, Financial Crime Compliance, Shall Establish Appropriate Governance Structures For All Areas Under Their Control And Shall:
Framework
Support The Group Head Of Financial Crime With:
- Develop, recommend and implement the annual and long-term strategy for the Function globally, as appropriate, as part of the overall Group strategy.
- Ensure that the strength, quality and capabilities of the Function are consistent with the stated strategy of the Group.
- Ensure that the Function is operating efficiently and effectively, including the identification, management and reporting of risks.
- Ensure that the Function (including any legal entities) is operating within the requirements of all appropriate laws and regulations.
- Ensure that appropriate succession and development plans are in place for the continued effectiveness of the Function.
- Ensure that the Function is effectively managed, raising performance through robust performance appraisals and performance improvement plans for under-performers.
- Ensure that delegated responsibilities are clearly identified and documented.
Functional Management
Support The Group Head Of Financial Crime With:
- Ensure that the strength, quality and capabilities of the Function are consistent with the stated strategy of the Group
- Ensure that the Function is operating efficiently and effectively, including the identification, management and reporting of risks
- Ensure that appropriate succession and development plans are in place for the continued effectiveness of the Function
- Ensure that the Function is effectively managed, raising performance through robust performance appraisals and performance improvement plans for under-performers
- Manage, retain and develop key talent within the team, ensuring individual development plans are in place
- Ensure that delegated responsibilities are clearly identified and documented.
Advisory
Support The Group Head Of Financial Crime With:
- Making judgements and decisions/recommendations on appropriate actions in relation to financial crime issues escalated from within the Group
- Providing advice on procedures and controls relating to regulatory and legislative issues concerning financial crime prevention.
Monitoring & Reporting
Support The Group Head Of Financial Crime With:
- Monitor the operation and effectiveness of anti-financial crime compliance systems and controls and providing a report on this to senior management.
- Monitor the effectiveness of arrangements with Third Parties e.g. Transfer Agents on whom reliance is placed for assessing risk faced by clients on our behalf
- Delivery of the assessment necessary for, and production of, the Annual Global Financial Crime Risk Report
- Develop and deliver Management Information and Annual reports to the relevant Boards and Committees
- Ensure that the Function (including any legal entities) is operating within the requirements of all appropriate laws and regulations.
Investigations
Support The Group Head Of Financial Crime With:
- Investigate internal and external reports of suspicious activity and make onward reports to relevant law enforcement agencies where appropriate
- Investigate Whistleblowing reports as required
- Respond to law enforcement enquiries or investigations on financial crime issues as required.
Represent the Group externally on Financial Crime Risk Matters
Support The Group Head Of Financial Crime With:
- Attend appropriate industry groups to keep abreast of current or prospective regulatory developments and industry best practices and, where necessary, articulate our views.
Reporting
- In discharging their responsibilities, the Senior Manager, Financial Crime Compliance shall:
- As appropriate, ensure that the Group Head of Financial Crime is made aware of any issues which the Financial Crime Compliance Senior Manager deems as material and which should be communicated to the Group Management Committee, the Group Risk Committee, the Chairman and/or the Board.
- As appropriate, ensure that the Group Head of Financial Crime is made aware of any issues which the Financial Crime Compliance Senior Manager deems as material and should be communicated to the Board Audit and Risk Committee.
- Provide to the Group Head of Financial Crime Compliance, an annual assessment of their own performance against objectives agreed with them.
- Provide annual reports to the mentioned UK Boards, supporting input into the Board Audit and Risk Committee, the Group Risk Committee (GRC) and the financial Crime Committee (FCC).
ABOUT US
We're a global investment manager. We help institutions, intermediaries and individuals around the world invest money to meet their goals, fulfil their ambitions, and prepare for the future.
We have around 6,000 people on six continents. And we've been around for over 200 years, but keep adapting as society and technology changes. What doesn't change is our commitment to helping our clients, and society, prosper.
