Job title: Compliance Officer
• To support the DMLRO in discharging their AML Financial Crime responsibilities to the Bank.
• To assist the DMLRO in the discharging of an effective SMF16 “Compliance Oversight”, SMF17 “Money Laundering Reporting Officer” responsibilities at all times.
• To ensure that the Bank remains fully in compliance with all statutory and regulatory obligations through active management of all aspects of financial crime, in addition to assisting in the development of responses to new regulatory developments.
• To assist in the undertaking of compliance monitoring of the Banks adherence to policies and procedures in working practice throughout the operational environments end to end process, (from origination through to decision in principle and monitoring of back end outsourced servicing for the Bank).
• To assist in the operational aspects of the newly created residential Home Purchase Plans (HPP) and Unregulated Mortgages. To assist in ensuring appropriate compliance oversight (adherence to MCOB and all other associated relevant regulatory rules), over the operational environment from origination to back end service provided to the Bank (under SYSC8).
Gatehouse Bank is a subsidiary of Gatehouse Financial Group Limited, which is a holding company for Gatehouse Bank (based in London and Milton Keynes) and Gatehouse Capital (based in Kuwait). Gatehouse Bank is a Shariah-compliant bank offering savings products and finance for UK commercial and residential real estate, in addition to sourcing and advising on UK real estate investments with a focus on the build to rent sector.
- To develop and work up to deputising for the DMLRO in their absence and contribute professional experience and gravitas to the management of the Bank’s anti-money laundering policies and procedures.
- To assist in managing the full AML cycle from client on-boarding to monitoring and reporting, and to manage all aspects of financial crime
- To assist the DMLRO in identifying, assessing, mitigating, and controlling all financial crime risks and transaction monitoring issues proactively (Financial crime systems and controls, Fraud, electronic crime, Money Laundering, Terrorist Financing, Bribery and Corruption, Market Abuse, Insider Dealing, Sanctions and Asset Freezes, and Information Data Security) and, when required, undertake the full scope of the DMLRO role with respect to financial crime risks in the DMLRO’s absence.
- An assessment of the effectiveness and robustness of the Anti-Money Laundering controls is carried out as part of the Compliance Monitoring programme. Anti-Money associated procedures are reviewed annually. Assisting in the review of the firm’s policies and procedures for countering the risk that the firm might be used to further financial crime.
- To assist as required in provision of an annual MLRO report to the Board Risk & Compliance Committee. “BRC”), delivering the status and issues relating to money laundering, terrorist financing, financial fraud and Anti Bribery
- To assist in Identification of the money laundering risks, the DMLRO considers a range of factors to be taken into consideration, These include, the customer base and products of Gatehouse Bank plc, the distribution channel used, the complexity and volumes of transactions and the operating environment
- To establish and demonstrate thorough knowledge of all relevant requirements including those of FATF, JMLSG, EU ML Directives, the sanctions regime, the Bribery Act and to translate these requirements into policies and procedures for the Bank.
- To develop subject matter expertise of all AML/financial crime requirements relevant to the Bank in the form of policies, procedures and training.
- To assist in ensuring an embedded and robust process and procedure in operation around on-going transaction monitoring, client on-boarding and ongoing periodic reviews that fully complies with the Bank’s KYC/AML policy and CDD procedures inclusive of the requirements of the regulations. Ensuring provision of compliance monitoring oversight is delivered over the first line of defence.
- To support the VP Compliance and DMLRO in delivering the compliance objectives of the Bank including, but not limited to, review and analysis of existing and proposed laws / regulations to determine impact on the Bank, across the operational controls environment of MK and Mayfair offices respectively.
- To assist in overseeing that all members of staff undergo desktop training regarding Anti-Money Laundering, Bribery and Corruption and Integrity Matters etc. The training modules are provided and supported by CISI. Ensuring also that the Training on Financial Economic Crime has been developed internally and is rolled out to all members of staff.
- To assist in the assessment of the effectiveness and robustness of the Anti-Money Laundering controls carried out as part of the Compliance Monitoring programme, ensuring Anti-Money Laundering associated procedures are reviewed annually.
- To assist in the provision of monthly updates and explanatory materials on regulatory developments and related compliance tools including suitable training programme to ensure compliance with applicable regulations. To also develop responses to regulators and other external bodies as appropriate on new regulations to promote the development of the Bank’s businesses.
- To advise the business on proposed activities and their regulatory impact from a financial crime perspective.
- To assist in the delivery of training to the employees bot ad-hoc or bespoke and ongoing training to ensure that the employees remain competent.
- To assist in monitoring of client reviews of a customer’s documentation and transactions including monitoring on sanctions screening systems to provide a level of assurance that the financial crime risk to the firm is mitigated.
- To assist in providing oversight through compliance transaction monitoring to highlight any identified first line of defence breaches in the process of undertaking client on boarding with compliance to the requisite policies and procedures and ensure an annual review of a client’s documentation remains current on a periodic basis for high risk clients
- To assist in implementing and manage the Data Protection framework and to keep up to date the Data Protection policies and procedures and to disseminate the new rules/regulations on Data Protection Act to staff.
- To assist the DMLRO to act as custodian and to keep records of all correspondences with the PRA, the FCA and other regulators as appropriate
- To engage with the Deal Team process from inception and ensure that all areas of Compliance are addressed and signed-off on the deal structure, counterparties, advisors, etc.
- To document, manage and monitor the Bank’s Anti-Bribery & Corruption and Economic Trade and Sanctions procedures and controls.
- To assist in ensuring Customer complaints handling is appropriately addressed within the time-lines agreed as internal procedure in alignment with the firm's compliance with DISP.
- To assist in compliance monitoring, Incidents and Breaches, Policies and Procedures, DPO Oversight, Audits/FCA requests.
- To assist in provision of Advisory services to Commercial Property Finance, Real Estate Finance and Treasury, Unregulated Buy To Let and HPP.
- To assist the Compliance Officer and MLRO in ensuring appropriate MI is provided; training to the business; Committee representation; SCV review; Projects co-ordination; Compliance root cause analysis; 1st LOD remedial action points; Financial Crime; Customer documentation & Conduct Risk.
- As required, travel to MK to provide compliance assistance.
- Assist in the monitoring of the business assurance teams and origination team process as it relates to KYC on-boarding issues.
- To assist in the delivery of ad-hoc, bespoke and ongoing training to ensure employees remain competent.
In addition to the responsibilities summarised above, you are required to comply at all times with the Conduct Rules set out in the FCA Handbook and the PRA Rulebook. These are listed below. Rules 1 to 5 apply to you by virtue of your employment with Gatehouse Bank and the nature of your role.
Rule 1 You must act with integrity.
Rule 2 You must act with due skill, care and diligence.
Rule 3 You must be open and cooperative with the FCA, the PRA and other regulators.
Rule 4 You must pay due regard to the interests of customers and treat them fairly.
Rule 5 You must observe proper standards of market conduct.
Qualifications and experience
Islamic Finance Qualifications (IFQ);
Team management / leadership;
CISI Investment Advice Diploma Level 4, International Compliance Diploma (ICA), CAMS or other relevant qualification
Good banking experience in a compliance officer role and relevant experience of assistance to a DMLRO role.
Required skills and knowledge
- Good knowledge of banking and investment principles
- Good knowledge of Real Estate Finance, Real Estate Investments, SPV investment transaction
- Knowledge of AML, Anti Bribery and Corruption and Data Protection Act
- General Compliance and MCOB specialism, Real Estate Advisory Experience
- Good writing, communication and presentation skills
- Good interpersonal skills and ability to build good working relationships with colleagues at all levels
- Self starting and able to work autonomously
- Must be innovative, providing solutions which are appropriate for the business and fit for purpose
We offer highly attractive reward package; the typical benefits include:
• 25 days holiday entitlement increasing with service
• Pension Plan
• Private medical insurance
• Critical illness cover
Gatehouse Bank is an equal opportunities employer and positively encourages applications from suitably qualified and eligible candidates regardless of sex, race, disability, age, sexual orientation, gender reassignment, religion or belief, marital status, or pregnancy and maternity.
To apply, please send your CV to Careers@gatehousebank.com