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The Chief Compliance Officer is responsible for ensuring there is a strong policy environment to ensure compliance with BSP regulations. This role will also conduct reviews of clients to ensure they are also meeting the compliance (and other risk) requirements of the bank. This will involve oversight of:
Compliance and Policy development, Defining policies, within the areas of operational policy AML policy IT and information risk policy, etc. o Maintenance of Compliance Monitoring System o Compliance reporting o Applications to the BSP Compliance reviews of partners o Ensure partners (both origination / cash management partners and system providers) meet the requirements of regulatory authorities o Provide inputs into Risk Assessment of partners Management of risk reviews of partners Ensure documentation of risk reviews of partners is complete, approved to the right level internal Audit reviews of partner policies Prioritize internal audit processes based on risk assessments Review internal processes Reviews processes of external partners Monitor exceptions and reports and provide feedback to partner-facing teams. reporting Secretariat to the Risk Committee, Audit and Compliance Committee Ensure adequate AML coverage This position shall serve as the following regulated positions: Chief Compliance Officer and AMLO Deeply understand the regulatory requirements and understand what specifically will be required to implement these requirements in the case of a partnership based bank.
Creatively find solutions Understand the practical implications of policies and identify solutions which meet regulatory requirements yet also meet the requirements of bank's clients.
As per regulation, this position will report directly to the independent Risk and Audit / Compliance Committees. The position will, however, work closely with the Head of Operations / CEO in the implementation of duties.
Metrics to monitor
On time implementation of: o Partner risk reviews Policy development plan
BSP assessment of the bank's performance (BSP rating)
Feedback from partner facing teams
Required skills and qualifications
This position requires expertise in control functions, while also understanding the implications of these functions on business operations to ensure the functions are implemented in a client friendly manner.
At least 8 years of Sr Management of Compliance ideally from the bank or fintech companies
The specific areas of expertise seen in the candidate will include:
Compliance expertise / knowledge of BSP regulations
Experience in communications with the BSP
Definition of a compliance plan
Experience in policy development. Clear and concise writing
Relevant expertise in compliance / legal background allowing the candidate to be approved by the BSP
Definition of risk management processes, including o Operational risk reviews o Market and liquidity risk o IT risk management, including responsibilities of the information security officer
Leadership of internal audit functions o Definition of audit timetable o Oversight of audit functions o Management of internal and external reviews
Initial tasks:
Review current policies, identify gaps in overall framework.
Complete policy in:
o Information risk management
Review the partner risk reviews to determine:
o Are there partners whose risk reviews need to be updated to reflect any newly identified issues? o Are there partners whose internal processes need to be reviewed?
Ensure compliance with AML regime ensure there are AML policies in place for partners Continue to implement the compliance regime, compliance reporting.
