Location: Edinburgh

Working Pattern: Hybrid

Role Description

The Financial Crime Manager manages the 1LOD team ensuring that FNZ (UK) Ltd carries out its financial crime obligations under Financial Crime legislation and FCA guidance with due skill, care and diligence and engaging as appropriate with 2LOD Regulatory Financial Crime Oversight.

Team Responsibilities

Providing financial crime expertise in relation to the financial crime legislation and risks, carrying out financial crime 1LOD activities and supporting the AML administration undertaken by FNZ (UK) Ltd (‘FNZ UK’).

Specific Role Responsibilities

Specific role responsibilities will include

Managing and undertaking as necessary the following activities:

Managing 1LOD Financial Crime Team

• Managing team member(s) and providing oversight in relation to the activities carried out by the team ensuring

• Appropriate procedures are in place and regularly reviewed

• Assigning activities to be undertaken

• Carrying out performance reviews

• Rating team member competencies on Skills Base  

• Ensuring appropriate controls and checklists are on Axiom as required

• Producing appropriate MI and reporting

• Ensuring business continuity for Financial Crime team activities in place

Financial Crime Risk Assessment

• Produce the Business Unit Risk Assessment (‘BURA’) Report by co-ordinating relevant risk assessments of business units. 

• Manage the actions plans from the BURA report.

• Review the business unit/team Risk Control Self-Assessments (‘RCSA’) and provide challenge to those business units/teams in relation to Financial Crime risks and controls contained therein.

• Assess new client/material proposition financial crime risks and work with the business to ensure that these are managed/mitigated and the RCSA is considered and amended to reflect any new or increased risks. 

• Assist the Head of Operational Risk & Control with recommending / assessing Financial Crime related KRMs and KPIs.

• Draft and request waivers, exceptions and breaches including reporting in relation to Financial Crime policy, standards and procedures.

Culture and Training

• Oversee and assist in the implementation of an Anti-Financial Crime culture within FNZ UK, providing recommendations on appropriate strategies to improve awareness of how financial crime may occur within 1LOD and the measures and oversight that require to be in place to prevent it occurring.

• Assist in drawing up and communicating an Anti-Financial Crime communications strategy and outputs.

• Assist in providing input and communicating the Financial Crime Policies and Procedures to the business.

• Provide induction training as required on Financial Crime.

• Provide role/specific financial crime training as required to Business Units carrying out Financial Crime/AML administration. 

• Provide input and assistance to 2LOD Financial Crime as part of the FNZ Financial Crime Mandatory Training annual refresh.

Financial Crime Governance

• Assist in implementing and executing a Financial Crime Governance Structure.

• Assist in defining and maintaining Financial Crime reporting framework (minimum reporting requirements).

• Be the delegate Chair on behalf of the Chief Operating Officer of the Financial Crime Committee, organising the scheduling of the Committee, co-ordinating the inputs to the Committee papers and tracking the actions.  Also ensuring that the Committee reflects the Terms of Reference and there is an annual review of those Terms of Reference and effectiveness of the Committee.

Financial Crime Activities

Provide management oversight/carry out following as required

• Provide advisory services to 1LOD employees in relation to Financial Crime and AML administration.

• Investigate and respond on any referrals sent to the 1LOD Financial Crime team in relation to activities such as AML, PEP, Sanctions and fraud checks carried out by the 1LOD administrators.

• Complete Financial Crime questions in RFPs for new business or propositions that relate to the Financial Crime administration carried out for clients by FNZ.

• Assist Projects in relation to new business / propositional engagement on Financial Crime administration including attending workshops as required.

• Assist 1LOD in relation to defining any new workflows/procedures relating to Financial Crime / AML administration.

• Host regular meetings with 2LOD Regulatory Financial Crime Oversight and 1LOD AML administrators within each FNZ business unit undertaking financial crime administration for clients.

• Build up working relationships with the Financial Crime teams of clients that FNZ UK carry out AML administration tasks for including attending regular meetings with them as required.

• Receive, investigate and respond to client queries in relation to potential fraud on their platforms relating to their customers.

• Escalate any external suspicious activities reports (i.e. relating to their customers) to clients.

• Complete Financial Crime sections of clients’ due diligence questionnaires and assist with any due diligence visits / any audits by clients related to Financial Crime.

• Assist with any regulatory changes connected to Financial Crime in particular any that impact AML administration carried out for clients.

• Undertake Financial crime due diligence on new and existing third parties when notified by Procurement/Supplier Management team.

• Build up relationships with the third parties connected to Financial Crime administration such as Experian and Tonbeller to build up knowledge to assist FNZ employees and clients with issues encountered.

• Provide consultancy and assist clients with the configuration, maintenance and set-up of clients’ rules and weightings within Financial Crime third party systems as required. 

• Work with clients to provide regular analytics and optimisation outputs in relation to the PEP and Sanctions checking carried out, where required.

• Complete AML comfort letters and other financial crime related documentation pertaining to fund manager account opening and ongoing due diligence.

Financial Crime Quality Assurance

• Carry out monthly sample checking on PES exceptions to ensure that systems access requested correlates to what was granted and staff do not have any additional access until they have fully passed PES checks.

• Assist with/carry out regular quality assurance checks on the 1LOD administration units that undertake the Financial Crime/AML administration which is outsourced to FNZ UK.

• Review AML administration procedures across Business Units following their annual review and update of procedures, checking that that Business Unit review has been carried out. 

• Carry out investigation on any internal monitoring alerts/red flags reports which are generated on FNZ staff to satisfy there are no financial crime concerns and if there are refer these to 2LOD Financial Crime

• Carry out additional assurance work on Financial Crime as required.

1LOD Financial Crime / 2LOD Regulatory Financial Crime Oversight (‘2LOD FC’) Engagement

• Build working relationship with the 2LOD FC ensuring that there is clear, open and timely communication.

• Escalate any suspicious activities reports / internal fraud alerts immediately to 2LOD FC.

• Engage with 2LOD FC in relation to the Financial Crime RCSA risks as agreed with 2LOD FC.

• Assist 2LOD Regulatory Financial Crime Oversight and, as applicable, other Business Units in FNZ UK with the review and refresh of Financial Crime risk assessments such as AML, Bribery and Corruption, Tax Evasion and Financial Crime.

• Assist with the organisation and content of the Financial Crime User Forum.

Performance Assessment

• Meeting regulatory requirements in connection with financial crime.

• Building awareness of financial crime within FNZ UK.

• Positive interaction with and feedback from clients in relation to financial crime.

• Bringing new ideas and initiatives to FNZ UK in relation to financial crime.

• Ability to work both individually and as part of a team to achieve FNZ UK financial crime objectives.

Experience required

• Good experience identifying and investigating potential customer fraud.

• Good knowledge on financial crime systems (preferably AML, PEPs and Sanctions) and experience in understanding the set up and configuration of rules and parameters.

• Experience at checking and discounting / verifying possible PEP and Sanction matches.

• Good working knowledge gained within financial services industry of identifying financial crime risks and implementing/overseeing suitable controls to mitigate those risks

• Good knowledge of UK Money Laundering Regulations

• Knowledge of Bribery Act 2010.

• Awareness and knowledge on other Financial Crime typologies such as fraud (internal and external), market abuse/insider dealing and Tax evasion.

• Desirable to have experience and knowledge of Financial Crime products/tools such as Experian, Tonbeller, Dow Jones, Cybersource and other industry financial crime solutions.

• Desirable to hold an industry known financial crime qualification such as an ICA Diploma or Certificate, but this is not essential.

• Good stakeholder management and communicating and influencing skills

About FNZ

FNZ is the market leading provider of technology and administration services to major financial institutions in the platform and wealth management sectors across the globe. We partner with life companies, banks, asset managers and discretionary wealth managers to enable them to develop and distribute financial products and services to their customers across all major distribution channels.

FNZ has a strong blue-chip customer base including Standard Life, AMP, National Australia Bank, Bank of New Zealand, UBS and Zurich Financial. It has helped these customers grow to around £80 billion of platform assets in aggregate. FNZ now employs over 1000 people with offices in Edinburgh, London, Bristol, Brno (Czech Republic), Wellington Sydney, Singapore and Hong Kong.

Opportunities

• Be part of a highly successful, rapidly growing, global business that is leading the delivery of financial services via cloud computing and partners with some of the world’s largest companies.

• Remuneration and career advancement is based on individual contribution and business impact rather than tenure or seniority.

• We provide global career opportunities for our best employees at any of our offices in the UK, Czech Republic, Asia, Australia or New Zealand.

About FNZ

FNZ is committed to opening up wealth so that everyone, everywhere can invest in their future on their terms. We know the foundation to do that already exists in the wealth management industry, but complexity holds firms back. 

We created wealth’s growth platform to help. We provide a global, end-to-end wealth management platform that integrates modern technology with business and investment operations. All in a regulated financial institution. 

We partner with over 650 financial institutions and 12,000 wealth managers, with US$1.5 trillion in assets under administration (AUA).

Together with our customers, we help over 20 million people from all wealth segments to invest in their future.