Main Job Purpose:

BNPP includes matters relating to Anti-Money Laundering (AML), Countering Financing of Terrorism (CFT), Countering Proliferation Financing (CPF) and financial sanctions under a single Compliance domain called ‘Financial Security’ (FS).

The Financial Security Compliance Manager, based in Jersey, leads in respect of the core FS framework under the responsibility of the Compliance Department for all BNPP entities across the Channel Islands. The role entails ensuring that the Group FS framework and related transversal Channel Islands requirements are applied consistently across both islands which involves liaising with the Guernsey Compliance Officer to ensure local specificities are taken into account. This includes the following matters:

NB: M&S is under the Market Integrity (MI) domain whilst interlinking with FS.

The Financial Security Compliance Manager also acts as the named Money Laundering Compliance Officer and Money Laundering Reporting Officer in respect of certain licences held by the BNPP entities in Jersey and undertakes the corresponding duties in accordance with the local applicable regulation and BNP Paribas policies and procedures. As this role simultaneously covers topics related to Market Abuse and Surveillance under Market Integrity domain, the role holder also acts as the joint Market Integrity Reporting Officer (MIRO) for 2S Channel Islands.

The role holder also supports the Territory Head of Compliance in the day-to-day execution and management of the compliance framework of BNP Paribas Channel Islands, ensuring activities are organised and executed in accordance with the requirements of the applicable regulatory framework, professional and ethical standards. Scope includes the domains of Financial Security, Market Integrity, Protecting the Interests of Clients (PIC), Professional Ethics (PE) and certain regulatory topics falling within the remit of the Compliance Function as may be directed from time to time. This scope includes transversal responsibilities such as compliance monitoring, training, contributing to policies and procedures, maintaining registers, advising business teams and reporting.

Key responsibilities:

Keep the business line management as well as the Compliance Department appraised of developments in terms of the laws, regulations, codes of conduct or standards within the compliance area applicable to the activities, and provide guidance on the interpretation and application of the requirements. Assist with providing advice and alerting the entity management and employees on matters of compliance. This may include specific transactional advice on matters such as cannabis-related regulation, sanctions and virtual assets.

Analyse and advise on local regulatory texts that relate to the above-mentioned topics, including, but not limited to, the Jersey Codes of Practice and the Jersey AML/CFT/CPF Handbook. 

• Foster an open and transparent relationship with the Jersey Financial Services Commission (JFSC) and other applicable authorities. This includes contributing to any requests, visits and inspections, as well as timely notifications to the regulators of any reportable matters.
• Implement and/or follow up recommendations made by the General Inspection, audits (internal or external) and the regulators, regarding the compliance risks, with the entity management.
• Provide support and advice on AML/CFT/CPF and sanctions issues and the potential regulatory, criminal and reputational risk associated with new and existing clients. Act as entry point for complex or technical due diligence issues.
• Provide independent judgment on any professional ethical matters, such as personal account dealing, gifts and entertainment, conflicts of interest, whether they relate to internal (within the company) or to external matters (including clients’ complaints). Act in the roles of PE Officer, PIC Reporting Officer and MI Reporting Officer as may be agreed with the Line Manager (supplemental job descriptions apply).
• Act as an entry point to provide expertise and advice on matters within the Compliance domains. This includes advice in respect to:

• Identify, evaluate and mitigate compliance risks by examining all new activities, products, and exceptional transactions to ensure compliance with regulatory and BNP Paribas requirements. Manage the Compliance Risk Management System (CRMS) annual questionnaires and perform the check and challenge of the Risk and Control Self-Assessment (RCSA).
• Manage the comprehensive compliance monitoring plan covering the key regulatory requirements, ensure major findings are reported to the entity management committees (as appropriate) and follow-up corrective actions, in conjunction with permanent controls.
• Identify, receive, record and follow-up regulatory breaches, compliance-related incidents and compliance-related complaints, advise on relevant actions to avoid re-occurrence and ensure that corrective measures to compliance-related problems have been implemented in an appropriate manner and have proved their effectiveness. Ensure registers are maintained for accurate record keeping.
• Manage and develop systems and controls (including policies and procedures) in line with evolving requirements within the compliance perimeter.
• May act as Whistleblowing Referent or Backup Referent if so appointed, in which case the relevant description of responsibilities will apply.
• May act as Anti-Bribery and Corruption Officer if so appointed, in which case the relevant description of responsibilities will apply.
• Ensure that a training programme is developed and implemented with the support of HR to ensure that all staff are appropriately trained on compliance requirements within the compliance area and maintain a strong compliance culture with the support of the entity management.
• Provide and deliver reports on compliance risks and activities to the management committee / boards in order to inform on regulatory developments in terms of compliance, to report on progress of compliance actions and to alert on risks of an ethical or compliance related nature. Represent the department in various board and committee meetings as part of the corporate governance framework.

The Head of Financial Security Compliance provides reasonable assurance to the Territory Head of Compliance and to the entity management, through opinions, supervision and daily tasks, of the efficiency and consistency of the FS and M&S framework. He / she specifically:

• Provides support and advice on FS and M&S issues and the potential regulatory, criminal and reputational risk associated with new and existing clients.
• Acts as escalation point for complex or technical FS and M&S issues. 
• Advises the business about Group and local requirements on more complex and non-standard transactions.
• Manages the tools and oversight of alerts issued by Group for detecting money laundering, sanctions hits, M&S and monitoring suspicious activities.
• Reports key FS, KYC, and M&S metrics to the relevant entity governing bodies.
• Supervises and coordinates the implementation and organisation of the CI Compliance framework in terms of FS, M&S, and the fight against bribery and corruption.
• Supports the Bank's efforts to build consistent and comprehensive client data framework, ensuring compliance with regulatory requirements.
• Identifies improvement areas and drives industrialisation and simplification initiatives across FS and M&S policies, processes and tools.
• Performs oversight on any remediation projects linked to FS and M&S, in close cooperation with business correspondents.
• Ensures consistent deployment of Group Compliance FS and M&S policies and procedures across BNPP CI entities.
• Reports Compliance risks within his/her perimeter, specific issues and mitigation plans to the Territory Head of Compliance and the Group Compliance (e.g. results on control plans and follow up of subsequent action plans).
• Makes Compliance decisions and/or delivers advice on issues reported by local and central teams, in accordance with Group escalation processes.
• Represents KYC and FS domains as an invitee to the CI Compliance Management Committee.
• If assisted by team members, establishes an appropriate organisation of resources placed under his/her responsibility.
• Manages and acts as local business owner of certain Compliance tools as agreed with the Territory Head of Compliance.
• Receives and considers internal SARs in accordance with internal reporting procedures to ensure SARs are being handled in an appropriate and consistent manner.
• Maintains a record of all requests for information from law enforcement authorities and records relating to all internal and external SARs.
• Reports suspicious activity to Group Compliance via the CANOPY tool.
• Ensures oversight of outsourcing arrangements with Group and external service providers regarding FS and M&S processes.
• Acts as a primary point of contact for the JFSC, FIU-Jersey, and the Minister for External Relations in relation to FS and market abuse matters concerning the BNPP licensed activity in Jersey.

 Jersey Regulatory Positions

• Undertake the duties and responsibilities specified in local legislation and guidance provided by the JFSC.
• Supplemental job descriptions relating to the regulated positions of CO, MLCO and MLRO apply.

 Technical skills - Essential Requirements

• Strong written and verbal communication skills.
• Strong record keeping skills and ability to manage data.
• Ability to analyse problems and work independently to propose solutions.
• Ability to interpret, apply and advise on regulatory requirements as may be introduced or developed from time to time.
• Good Computer literacy across a variety of common applications. 
• Strong computer literacy across a variety of common applications.
• Sound knowledge of the Jersey regulations.
• Project management ability.

Qualifications and industry experience - Essential Requirements

• Previous experience as CO, MLCO or MLRO.
• Recognised professional financial services qualification. Qualifications in compliance, risk, governance, accountancy and/or law would be ideal.

Competencies - Essential Requirements

 Training:

• All employees complete on-line AML/CFT/CPF and sanctions, market abuse surveillance and ethics related training.
• The employee is expected to keep up to date with regulatory developments.
• Full training on systems and controls.
• Periodic ACAMS webinars for Certified Anti-Money Laundering Specialist (CAMS) Recertification every 3 years 
• Annual International Financial Sanctions Compliance Officer (IFSCO) Continuing Education Program

Qualifications supported:

• International Compliance Association “ICA” (compliance related).
• Other applicable qualifications as agreed with the Line Manager.
• CAMS
• Certified IFSCO

Manager conduct responsibilities:

In a controlled risk environment and in alignment with the global strategy, managers must ensure full compliance with Conduct policies:

• Ensure Conduct governance is fully operational, as per standard guidelines: Conduct is a standard item at the agenda of management or team meetings, Conduct dilemma are well managed and documented, the escalation process is in place, Conduct responsibilities are delegated throughout the perimeter in charge.
• Be aware of the Conduct risks arising in the perimeter in charge and make sure that appropriate mitigating processes and controls are in place.
• Ensure Conduct principles are fully embedded in processes including people management processes (appraisal, promotion, mobility, recruitment, …).
• Develop understanding of Conduct principles by ensuring staff participation to awareness & training sessions.

Regulatory requirements:

• The individual must submit a personal questionnaire for the Key Person roles of CO, MLRO and MLCO and ultimately receive confirmation of ‘no-objection’ from the JFSC.
• Current CPD requirement: 35 Hours
• Is the employee a “Principal Person”*? No 
• Is the employee a “Key Person”*? Yes 
• Is the employee a “Senior Manager”*? Yes 

*according to the meanings given under Article 1(1) of the Financial Services Commission (Jersey) Law 19981 as supplemented by the Commission’s Notice designating “senior management functions” dated 12 January 2023 and effective 13 March 2023.