This is a key second line of defense role within the Compliance function in Asia, based in the Hong Kong office.
The role is to ensure that activities of Sanne entities that are licenced and incorporated in the Asia Region are undertaken in accordance with the regulatory and statutory requirements and in accordance with Group procedures.
The role provides support to the Country Lead Compliance Officer ( CLCO ) to develop the Compliance framework in Asia, including the monitoring and testing of the business, and strengthen the Group compliance network and evolution of the group wide compliance capabilities.
Deputy MLRO (in the absence of the MLRO)
Receiving internal reports of suspected Money Laundering from within the business.
Review of internal reports of suspicion and determine whether it is necessary to file a suspicious transaction report ( STR ) with the relevant financial intelligence unit.
Reporting of STRs to Joint Financial Intelligence Unit (Hong Kong) or the Suspicious Transaction Reporting Office, Commercial Affairs Department of the Singapore Police Force (Singapore), with dual report to the Financial Reporting Authority (if applicable) for Cayman Funds.
Providing guidance to staff on how to avoid tipping off’ if an STR is filed.
Acting as the main point of contact with the relevant financial intelligence units, law enforcement agencies and any other competent authorities in relation to AML / CFT risk, investigation or compliance.
Making annual reports to senior management about Money Laundering compliance in respect of criminal property, Money Laundering and terrorist financing risks using the Sanne format.
Assistant Compliance Manager
Assist in acting as the focal point locally for the oversight of all activities relation to ML / FT in the Asia region.
This includes, but is not limited to Singapore and Hong Kong (as engaging entities) with oversight of China and any other offices in the Asia Pacific region as the company expands.
Providing support and guidance to the senior management in Asia to ensure that ML / FT risk is appropriately and adequately managed.
Assist in developing and reviewing the AML / CTF systems to ensure they remain up-to-date and meet current statutory and regulatory requirements.
Assist in overseeing all aspects of local AML / CFT systems which include monitoring effectiveness and enhancing the controls and procedures where necessary.
Support the CLCO by overseeing adequate arrangements in Asia for AML / CFT awareness and training in line with current legal and regulatory requirements.
Providing support and advice on AML / CFT issues and the potential legal, regulatory, criminal and reputational risk associated with new services, changes in business profile, new and existing customers.
Acting as the escalation point for complex or technical due diligence issues.
Reviewing AML / CFT websites and news sites ensuring any relevant information is portrayed to staff in order to mitigate AML / CFT risk.
Implementing and / or following up recommendations made by internal or external audits and the regulators, regarding compliance risks.
Support the CLCO in the implementation, periodic review and update of Regional Compliance Manuals for the SANNE entities in Asia to include any updates in group policy and local regulation.
Maintaining and Monitoring Regional Compliance Logs
Breaches and errors log
Conflicts of interest register
Maintains file of all correspondence with the relevant regulator
Support the CLCO in Regional Board and Group Reporting
Preparation of Sanne Asia Region Companies Risk and Compliance Report and presentation to Directors in quarterly board meetings.
Group Compliance reporting MI.
Skills / experience required
Specialist experience in Customer Due Diligence (CDD / KYC).
Sound understanding of multi-jurisdictional financial services regulation and AML guidelines.
Knowledge and experience in alternative asset and corporate administration services.
Motivated and driven with an ability to work under pressure to tight deadlines.
Understanding of global corporate structures.
A keen awareness of risk issues in the context of fiduciary responsibilities.
Ability to communicate, engage and build relationships across the organisation and externally.
Holder of relevant Compliance or Anti-Money Laundering professional qualification.