Purpose of the role:
The overall purpose of the role is to be the single point of contact for GVS Prepaid’s (GVSPE) regulatory requirements and anti-money laundering legislation in conjunction with other members of the Blackhawk EMEA Legal & Compliance team. This is a PCF-12 position for Head of Compliance and PCF-52 for Head of Anti-Money Laundering and Counter Terrorist Financing Compliance under the CBOI Fitness & Probity rules.
The role holder would also act in a consultative way in advising the Board and Senior Management on the effect of regulatory or legislative changes to business practices.
To develop and drive implementation of compliance within GVSPE, Agents & Distributors (in Ireland and Netherlands currently) to ensure that regulations and financial services best practice is achieved in this area.
Key Deliverables:
Responsibility for interpreting regulatory rules and the impact on GVSPE.
The role holder would be expected to be the internal subject matter expert (SME) for the Central Bank of Ireland (CBOI) rules. It is envisaged that this would include the maintenance of an internal working document, procedures, or knowledge base to ensure that regulatory information is shared and that there is no single point of failure in relation to the regulatory information gained.
Responsibility for ensuring that GVSPE is complying with the various regulatory rules.
The role holder would be responsible for ensuring that GVSPE is compliant with regulatory requirements including development and implementation of appropriate processes, measurement, and associated reporting of compliance-related activities.
External point of contact
The role holder would serve as the conduit between GVSPE and external parties such as the CBOI, law enforcement agencies, and partner processors, to ensure consistency of messages and responses. The role holder would be required to keep a record of all contacts and to develop the relationships to the benefit of GVSPE.
General
- Be approved as the PCF15 (Head of Compliance) & PCF52 (Head of Anti-Money Laundering and Counter Terrorist Financing Compliance) with the CBOI.
- Ensure that the firm demonstrates to the CBOI, the Board, Business Partners, and its customers, that it subscribes to regulatory best practice.
- Ensure the company has appropriate processes and procedures that meet regulatory requirements while maintaining a commercial focus.
- Support the business leaders in the strategic planning for the function and the review, enhancement, and implementation of risk-based financial crime prevention, detection procedures, and systems and controls.
- To advise management on and monitor compliance with Financial Promotion regulations.
- To work closely with GVS Prepaid Ltd (UK regulated entity), Blackhawk EMEA Legal & Compliance and develop joint approaches using best practice to benefit BHN EMEA.
Communications with the Regulators
- Primary point of contact with the CBOI and maintaining an appropriate relationship with the regulator.
- Ensure CBOI regulatory returns are filed on time (but not necessarily responsible for completion).
- Provide timely, accurate, and relevant compliance advice for all aspects of the regulated business.
- Produce regular compliance reports containing relevant Management Information for the Board and Senior Management on compliance-related matters.
- Keep abreast of all new legislation and how it affects the business and report to the Board and Senior management in this regard.
Procedures and Frameworks
- Ensure appropriate Compliance monitoring is undertaken, results reported and recommendations, where appropriate, deliver improvements to systems or procedures.
- Review and recommend updates to controls, policies, and procedures in line with business and legislative changes. Ensure that controls, where accepted, are documented and embedded with the business.
- Ensure that the compliance framework (second line of defence) enables senior management to effectively understand, manage, monitor, and mitigate the firm’s various compliance and regulatory risks.
Training
- Ensure employees at all levels are aware of the relevant compliance requirements and possible internal and external penalties for a breach of a law, regulation, or company rule.
- Design and deliver regulatory training to all employees in a manner that is appropriate to their role and seniority.
Suspicious Activity
- Be accountable for the firm’s financial crime obligations and compliance with the various pieces of legislation that impact on the business.
- Analyse Suspicious Transaction Reports referred for potential Money Laundering (ML), terrorist financing (TF) and fraud activity. Report to the authorities where appropriate.
- Ensure Sanctions/PEP alerts are reviewed and actioned accordingly to reduce the risk of the Group dealing with companies or individuals that might be subject to enhanced due diligence measures or that the group cannot do business with due to being sanctioned.
- Support all business areas through provision of operational advice and guidance in respect of the practical interpretation.
Skills
- Impact and Influence, both internal and external.
- Excellent communication skills, both oral and written.
- Stakeholder & Relationship Management.
- Time management and the ability to prioritise.
- Analytical skills.
- Commercial Awareness.
- Able to work effectively with minimal supervision.
Knowledge
- Excellent knowledge or an appreciation of CBOI rules and processes relating to electronic money, payment services, and financial promotion regulations.
- Qualification in Compliance or related qualification.
Experience
- Experience in managing a compliance function within a financial services business in Ireland preferably with experience in the payment’s arena.
- Ideally several years’ experience gained working within CBOI regulated firm.