Compliance Officer

Key responsibilities

Programme oversight

• Oversee the AML/CFT/CPF programme day to day and ensure continued compliance with FIAMLA and the Regulations, subject to the oversight of the board and senior management.
• Design, implement and maintain the internal compliance manuals, policies, procedures and systems.
• Own the business risk assessment: prepare it, keep it current, and obtain board approval at least annually and after material changes in law or business.

Customer due diligence and monitoring

• Ensure customer due diligence, enhanced due diligence, beneficial ownership checks, risk rating and ongoing monitoring are performed to the required standard.
• Oversee sanctions and PEP screening, including action on UN list updates and match resolution.
• Test customer files on a sample basis and track remediation of gaps.

Training and awareness

• Plan and deliver AML/CFT training for the board, management and all staff, and maintain attendance and test records.
• Make sure staff know who the MLRO and Deputy MLRO are and how to escalate suspicion.

Reporting and governance

• Report regularly to the board and senior management, including any non-compliance, open actions and regulatory developments.
• Maintain a compliance monitoring plan and a log of findings, with owners and deadlines.
• Keep the evidence file ready for audits and FIU inspections, and coordinate the business's response to them.

Regulatory liaison

• Monitor changes in AML/CFT law, regulations and FIU guidance, and update policies in good time.
• Support the MLRO in dealings with the FIU and other authorities.

Authority

• Unrestricted access, on request, to all books, records and employees as necessary for the role.
• Direct access to the board.
• Authority to stop or escalate onboarding or transactions that breach policy.
• A budget and resources sufficient to perform the role.

Qualifications and experience

• Degree in law, finance, accounting, compliance or a related field, or an equivalent professional qualification.
• [3 to 5] years of AML/CFT or compliance experience, ideally in real estate, financial services or another regulated sector.
• Working knowledge of FIAMLA, the FIAML Regulations 2018, the UN Sanctions Act and FIU guidelines.
• An AML qualification (for example ACAMS or ICA) is an advantage.

Skills and attributes

• Integrity, independence and the confidence to challenge senior colleagues.
• Clear written and spoken English and French.
• Strong organisation, analysis and reporting skills.
• Fit and proper: no criminal convictions, with checks carried out on appointment.

Independence and conflicts

The post holder must not hold sales, revenue or customer-relationship responsibilities that could conflict with compliance decisions. Any other duties must be documented and approved by the board.

Performance measures

• Business risk assessment and policies approved and current.
• Percentage of customer files meeting due diligence standards.
• Training completed on schedule.
• Open compliance actions closed by deadline.
• Timely and accurate regulatory inspection and audit outcomes.