Brown Brothers Harriman

At BBH we value diverse backgrounds, so if your experience looks a little different from what we've outlined and you think you can bring value to the role, we will still welcome your application!

What You Can Expect At BBH:

If you join BBH you will find a collaborative environment that enables you to step outside your role to add value wherever you can. You will have direct access to clients, information and experts across all business areas around the world. BBH will provide you with opportunities to grow your expertise, take on new challenges, and reinvent yourself—without leaving the firm. We encourage a culture of inclusion that values each employee’s unique perspective. We provide a high-quality benefits program emphasizing good health, financial security, and peace of mind. Ultimately we want you to have rewarding work with the flexibility to enjoy personal and family experiences at every career stage. Our BBH Cares program offers volunteer opportunities to give back to your community and help transform the lives of others.

Head of Compliance (PCF12) & Head of Anti-Money Laundering and Counter Terrorist Financing (PCF52)

Closing Date: 5th May 2024

The Head of Compliance (PCF12) & Head of Anti-Money Laundering and Counter Terrorist Financing (PCF52) will have overall responsibility for managing the operation of the compliance function (including AML / CTF & Sanctions compliance) and reporting directly to the Board, relevant Board committee, or both, on compliance, AML / CTF & Sanctions compliance matters. The role holder will be the primary contact point for all day-to-day issues, queries and advice to the Irish depositary business. In particular, the role will have responsibility for ensuring a second line oversight of the TSL outsourcing and AML / CTF frameworks. The role holder will manage the CBI relationship and all CBI inspections and reviews. The role holder will ensure reporting to and attendance at the various TSL governance committees and will also act as Data Protection Officer and Anti-Fraud Officer for TSL.

As a Pre-approval Controlled Function this role is subject to the Central Bank of Ireland’s Fitness & Probity requirements.

Duties include:

Compliance Policy, Process and Documentation

• Manage the development of compliance policy and provide support to the business units with regard to the impact of business developments on policy
• Oversee the annual AML / CTF / Sanctions Business Risk Assessment and ensure appropriate corresponding policies and procedures
• Managing the AML/CTF & Sanctions compliance function in order to address the
• TSL’s money laundering, terrorist financing & sanctions risks including the development and oversight of a robust AML/CTF/Sanctions framework; and overseeing the implementation and effective application of AML/CTF/Sanctions systems and controls
• Oversight of the review of customer complaints
• Oversight of the review and monitoring of employee disclosures regarding personal trading, outside business activities, etc 
• Oversight and review of incidents related to data loss or potential data loss
• Review regulatory consultant Independently identify and resolve problems following established guidelines, accounting for internal guidelines as well as outside regulatory requirements
• Execute a range of complex tasks and analyses including discussing proposed resolution with Compliance management
• Communicate compliance and regulatory requirements in both written and oral format to the management
• Proactively identify trends in recurring compliance violations and inquiries and collaborate with other team members to improve compliance procedures and processes, training materials and forms
• ion documents for changes to compliance requirements. Ensure reporting on the impact of these to line of business and compliance management globally.
• Manage the compliance reporting process to TSL senior management and board (including AML / CTF / Sanctions matters)
• Manage regulatory projects, meet deadlines according to a plan and produce management information relating to the project
• Review regulatory filings and ensure they are made in timely manner
• Assist in the requests for information from CBI, collect information and documentation and prepare applicable response for Compliance management
• Ensure that the Compliance manual for your area is reviewed on a regular basis and kept up to date with regulatory change

Compliance Advice, Issue Identification / Escalation and Business Planning

• Collaborate with senior management on changes to business procedure relative to compliance policies
• Ensure the ongoing maintenance of compliance procedures and ensure that procedures are complete and up-to-date
• Identify regulatory issues which may impact local business and work closely with the business to resolve those issues
• Identify AML/CFT/ Sanction regulatory issues which may impact local business and work with the Global Financial Crimes Compliance Department on the impact of these
• Liaise with Risk Management on related matters to ensure appropriate second line of defense coordination
• Assist in the provision of sound technical advice to the business as required together with solutions to complex regulatory issues.
• Recommend Action Plans and be able to implement recommendations

Compliance Problem Resolution

• Independently identify and resolve problems following established guidelines, accounting for internal guidelines as well as outside regulatory requirements
• Execute a range of complex tasks and analyses including discussing proposed resolution with Compliance management
• Communicate compliance and regulatory requirements in both written and oral format to the management
• Proactively identify trends in recurring compliance violations and inquiries and collaborate with other team members to improve compliance procedures and processes, training materials and forms

Compliance Team, Supervision, Training, Management and Business Training

• Oversee the delegation of day to day work to employees of the Dublin Compliance team as necessary and ability to coordinate locally and with the wider global Compliance team as required from time to time
• Prepare training materials and undertake employee training to the business (with support from business as considered necessary)
• Ensure training topics reflect current Compliance focus and that training material is updated to reflect any regulatory changes
• Provide training and support to other members of the Compliance team

Compliance Monitoring

• Work with team members to ensure that compliance monitoring program remains on track and relevant compliance processes have been appropriately documented
• Responsible for following up and closing out outstanding action points identified through the compliance monitoring program
• Undertake compliance monitoring program as required
• Review and document findings from compliance monitoring program including completing all working papers, notes of meetings, visit summaries and other compliance monitoring documentation in line with the compliance monitoring framework
• Review reports on findings prior to distribution to business managers
• Ensure that the compliance monitoring control schedules are updated on a timely basis
• Develop and maintain the Compliance Risk Assessment for your business area, as appropriate.
• Develop and maintain an annual Compliance Monitoring Plan for your business area, as appropriate
• Ensure that there is liaison with Internal Audit when planning compliance monitoring
• Compliance Operations
• Complete compliance operations processes as required
• Seek to eliminate bureaucracy and enhance efficiency
• Analyze Compliance team workflows to maximize operational efficiency
• Compare your local Compliance procedures with current regulatory requirements to implement any new technology that the department requires

REQUIREMENTS:

• Business / Finance / Law Degree and / or equivalent work experience
• 10+ years business or compliance experience (existing PCF role holder an advantage)
• Proven leadership skills
• Strong written and oral communication skills
• Proven technical compliance knowledge in respect of Irish Fund Service Provider regulatory compliance
• Capable of executing a range of complex tasks and analyses
• Ongoing compliance with the Central Bank of Ireland’s Fitness & Probity requirements
• Expertise in the financial services industry and current regulatory requirements as they relate to the Fund industry, incl. Alternatives Funds, related support function including depositary services
• Expertise of applicable Ireland banking or fund laws and regulation (as opposed to understanding/following procedure)
• Experience and knowledge of rules and standards including AML/KYC, Data Protection, Outsourcing and Anti-Fraud laws and regulations
• Client / Regulators facing skills and experience will be an advantage