Title: RC (MLRO & Compliance Manager)

Business: U.S. Bank Global Fund Services Luxembourg

Reports to: Primary reporting line to the Senior AML Manager – WCIB within the Gorup EFCC team. An indirect reporting line to the Senior Compliance Manager – Wealth within the Corporate Compliance team on Compliance related matters will apply.

Location: Luxembourg

U.S. Bank Enterprise Financial Crime Compliance (‘EFCC’) and Global Corporate Compliance (‘GCC’)

U.S. Bank Enterprise Financial Crime Compliance (EFCC) sits within U.S. Bank Risk Management and Financial Crime Global Enterprise and is part of the bank’s second line of defence. The role of EFCC includes but is not limited : (a) to provide formal assurance within the organisation and externally to regulators and other key stakeholders that U.S. Bank, its domestic and international subsidiaries and affiliates, including joint ventures and its subsidiaries are compliant with applicable regulations and legislation, (b) to provide advice and guidance to the Board and Senior Management on key Financial Crime Risk issues and, (c) to act as a control and advisory function in the three lines of defence. A core tenet of this is the provision of oversight and challenge in relation to the bank’s regulated activities. This is achieved, in the main, under the U.S. Bank’s AML Program.

Position: RC (MLRO & Compliance Manager) U.S. Bank Global Fund Services

U.S. Bank Global Fund Services Luxembourg is seeking an experienced candidate to join our team. This candidate must have strong knowledge of the AML, Sanctions and Compliance framework around Fund Administration Services in Luxembourg, Europe and non-European jurisdictions.  

The MLRO/Compliance Manager will act as the first point of contact for all AML/Compliance related matters within EFCC /GCC with oversight of the Fund Services business line in Luxembourg. The role will also include ensuring continued compliance with local jurisdictional requirements and to support the Local and wider Bank’s Board Members and Senior Management in discharging their legal /regulatory obligations.

The position will interact directly second line EFCC/GCC Europe centralised teams with local and Risk and Financial Crime CRO departments. The MLRO/ Compliance Manager is expected to be a sparring partner for 1st line business lines, risk partners and other key functions within Luxembourg and across the Enterprise.

In addition, the candidate must have the ability to work well with internal and external auditors and regulatory examiners by providing full cooperation and timely delivery of requested documentation and information. 

Due to the responsibilities associated with the role, adjustments to titles and internal reporting lines, in accordance with regulatory requirements may be deemed appropriate.

Principal Accountabilities of Position will include but not limited:

• Build out a strong EFCC/Compliance oversight with SME of Luxembourg Regulatory Requirements and Industry Practices within the Investment Services Business;
• Enhance the AML program in the various jurisdictions including but not exclusively AML/Economic Sanctions Risk Assessments and Local Country Requirements in accordance with guidelines or manuals issued by the Bank setting out the governance within those programs;
• Overseeing that the implementation of the AML Program is consistent with regulatory expectations and industry practice for the Global Fund Services business line;
• Oversee contact with regulatory bodies in co-operation with the U.S. Bank Regulatory Services team and the European EFCC/Compliance teams;
• Act as the point of escalation for Global Fund Services Luxembourg ;
• Facilitate, participate and consult in the execution of the Second and Third Line of Defence testing, Risk Assessment & Policy Implementation program and the business change program;
• Promote the Financial Crime & Compliance culture across GFS Luxembourg and the bank through active engagement with management, peers, direct reports, stakeholders, and other employees;
• Provide clear guidance and credible challenge to senior business leaders in their implementation of AML, Sanctions & Compliance controls;
• Represent Global Fund Services Luxembourg with other internal stakeholders promoting best practice and consistency across Luxembourg and the Enterprise including the Third Party AML service offering.  

 

Basic Qualifications:

• Bachelor's degree, LCOI, CAMS or other professional certification(s) in Financial Crime Compliance and Fund Services space will be favourably considered;
• 5-10 years of experience in a relevant Financial Crime Compliance Risk management environment preferably in the Investment Services Funds Industry.

Preferred Skills/Experience

• Expert knowledge of Luxembourg and EU AML regulations, FFIEC Examination Manual, USA PATRIOT Act, FinCEN guidance, FATF and other industry guidance and best practices;
• Minimum 5 years of experience with specific emphasis on work experience with a Fund Services Provider (a Fund or Fund Manager) in a Financial Crime Compliance Function;
• Understanding of Fund Services products i.e. Fund administration, Transfer Agent, Fund accounting and reporting, Fund custody and how they may be exploited for criminal purposes, including but not limited to money laundering, sanctions evasion and terrorist financing activities;
• Strong oral and written communication skills with the aptitude to establish credibility and collaborative partnerships with senior business leaders and global partners;
• Proven experience of interaction with the Board, Local Committees, Regulators and Auditors;
• Must possess business acumen and credibility to help business line(s) proactively identify and address changing workforce needs;
• Hold self and others accountable to consistently achieve meaningful results;
• Ability to operate in a matrix organisation, build relationships across business lines, and other functions. 

Competencies: 

• Is collaborative in approach with strong emphasis on delivery and execution;
• Exhibits a positive ‘can do’ attitude with excellent problem-solving skills;
• Adapt quickly to changing priorities; create new and better ways for the organisation to be successful;
• Maintain high ethical standards; gain the confidence and trust of others through honesty, integrity and authenticity;
• Demonstrates US Bank core behaviours on an ongoing basis.

U.S. Bank Core actions and behaviours: 

• Adapt quickly to changing priorities; create new and better ways for the organisation to be successful;
• Help others to continuously improve and achieve results;
• Explore multiple solutions to overcome obstacles;
• Anticipate future needs that may affect the team or organisation;
• Search for ways to enhance the customer experience;
• Set high standards of performance for self and team;
• Help others meet commitments, goals and deadlines;
• Achieve results that have a clear, positive and direct impact on the business;
• Meet commitments and persist despite setbacks or obstacles;
• Demonstrate our core values through words and actions;
• Treat others with professionalism and respect by honouring agreements and commitments, while managing priorities;
• Create a climate where people are motivated to help the organization achieve its objectives.