- Review of SAR escalations from the Financial Crime Compliance Investigation Team and where appropriate file them with the FIU;
- Review and approve escalations from the front office/first line of defence in regards to:
- Waivers;
- PEP Role Discounting;
- PEP Declassications;
- Exceptions from policy;
- Major negative media;
- EDD Approvals;
- Blacklist hits;
- Military/Dual Use Goods queries;
- Proliferation financing queries;
- Sanctions/Civil Penalty hit (in consultation with FCC Sanctions);
- Sanctioned Country Connection (in consultation with FCC Sanctions);
- Sanctioned Risk Assessments (in consultation with FCC Sanctions and subject to final approval from the Group MLRO);
- Financial Crime Investigations (in consultation with FCC Investigations and subject to final approval from the GMLRO);
- Sanctions Investigations (in consultation with FCC Sanctions and subject to final approval from the GMLRO);
- Dispensations (in consultation with FCC Advisory and subject to final approval from the GMLRO);
- Risk downgrades (in consultation with FCC Advisory and subject to final approval from the GMLRO);
- Liaise with the front office with any questions about policies and procedures;
- Assist to relevant Forums, Working Groups and Committees where Compliance/MLRO advice is needed;
- Keep up to date with relevant AML and Financial Crime regulations and changes;
- Policy drafting and reviewing, ensuring that the local policies and procedures are consistent with the group, but also ensuring that they are compliant with the applicable local regulations and laws;
- Conducting research for ad hoc regulatory queries from other departments or Senior Management;
- Be the direct contact person with the Regulator (Bank of Italy) and assure a good relationship and cooperation;
- Drafting and preparing the regulatory periodic deliverables and drafting regulatory communications;
- Coordinate as key point of contact for AML Audits (internal & external) and ensure that the information provided is accurate and up-to-date;
- Perform remediation works of findings by both internal and external audit, as well as recommendations set by the Regulator;
- Provide inputs to periodic financial crime management information;
- Identify local financial crime/regulatory training needs and provide training about products, financial crime, regulatory obligations etc. to the front office and sales teams;
- Ensure monitoring of the first line of defence from a second line of defence perspective to identify any issues and concerns;
- Assist the Regulatory Operations team in the implementation of AML Reporting by translating local legal requirements into operational guidelines. Liaise with regulators and other regulatory bodies to this end as appropriate;
- Identification and completion of local regulatory reporting requirements;
- Assist the business units and Senior Management with ad-hoc queries where appropriate (i.e. in scope and not already covered by a dedicated team e.g. KYC Advisory);
- Responsible for the complaints handling for the branch with the responsibility to communicate with the client, investigate the complaint and take decisions on the redress of the complaint (up to and including whether the complaint will be upheld or not);
- Manage relationships which are considered as having conflicts of interest and ensuring that the management rules set in place are followed by all parties. Conflicts of interest are dealt with at a group level, however, the Compliance Officer & MLRO is required to be aware and ensure that it takes actions agreed during the all stages;
- Assist in the investigations on breaches that involve the branch and assist in the investigation process with the group level compliance.
- Coordinate with the wider regulatory compliance team regarding applicable changes and implementation of new procedures and controls.
- The Financial Crime Working Group (monthly);
- Integral member of the local Client Risk Acceptance Forum (weekly); and
- Compliance Management Committee (weekly)
- Italian Client Review and Acceptance Forum (ad hoc)
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Compliance Officer - Milan, Italia - Ebury
Descrizione
Ebury is a hyper-growth FinTech firm, named in as one of the top FinTechs to work for by Glassdoor and AltFi. We offer a range of products including FX risk management, trade finance, currency accounts, international payments and API integration.
Compliance Officer & MLRO - Italy
Ebury Milan - 4 days a week office based working
The Italian Compliance Officer & MLRO, reports directly to the Head of Compliance in the EEA. The main purpose of the role is to maintain the integrity of the Italian branch, ensuring adherence to legislative requirements and providing support to the wider group. In addition this role requires oversight of regulatory obligations, requirements and implementing findings into policies and procedures. In their role, the Compliance Officer & MLRO is trusted with responsibilities which include:
As the position of Compliance Officer & MLRO is described as "independent" the responsible person in the role is expected to take decisions which may directly affect the branch and the overall business. The role of a Compliance Officer & MLRO is required to be senior enough to have the ability to take decisions on the ground to protect Ebury, its clients and its various counterparties. In their role, the Compliance Officer & MLRO participates in various working groups, committees and other important functions including:
Finally, the Compliance Officer & MLRO of the branch should maintain a good working relationship with the Country Manager, and would possess the right and ability to oppose decisions that are deemed to be non-compliant with our regulatory obligations, group policies and anything relating to financial crime. The person holding this position, by definition of the responsibilities assigned, will be deemed to be the most senior member of compliance in Italy with authority to take actions necessary to protect the integrity of Ebury and protect its licence and overall reputation.
Proficiency in English and Italian is required while any professional certifications or a law/economics degree will be considered a plus.
#LI-CD1
#LI-ONSITE
 Create drinks recipes Stay guests focused and provide excellent guests experience Help others when required. Maintain confidentiality of proprietary information; protect company assets. Support all co-workers and treat them with dignity and respect. Comply with quality assurance expectations and standards. Maintain bars as clean as possible and use quiet times to clean, tidy up What we’re looking for Possess a good command of English. Great storytelling skills. An excellent verbal manner and proven customer service skills. Good knowledge or experience of the hospitality industry. Good organization skills with an attention to detail. A team Player with flexible & positive attitude. Good leadership and training experience. Passion for the hospitality industry. Able to work in a fast paced environment & remain calm under pressure. Be able to demonstrate experience in complaint handling. Availability to work late nights, weekends and bank holiday as we operate 365 days a year.   Connect your passions with a rewarding opportunity You’re a beverage enthusiast. And with us, you'll get to both refine and showcase your craft of creating cocktails.  Join us and grow through opportunities to explore the business, opening yourself to various career options. No matter your path, we’ll make sure you feel right at home. Explore our very big world As a world-class leader in the travel industry, there’s no better place than Marriott International to make your mark. Joining us, you’ll get to entertain and meet people from all over the world as you build your experience. You’ll find a place where your personality and ideas are appreciated just as much as the work you do. And you’ll grow through opportunities to explore the business, opening yourself to various career options. If you have the natural ability to communicate and enjoy working with others, we welcome you to join our global family. Marriott International is an equal opportunity employer. We believe in hiring a diverse workforce and sustaining an inclusive, people-first culture. We are committed to non-discrimination on any protected basis, such as disability and veteran status, or any other basis covered under applicable law.&v=024){kind=logo}