Compliance Manager

Hours: Part-time or flexible, with scope to increase

Reports to: Managing Director (also acting MLRO and MLCO)

Our client is a Jersey-based chartered accountancy and tax advisory firm . A are a team of eight, looking after a mixed portfolio of Jersey individuals, companies, trusts and partnerships. The work spans accounts preparation, tax compliance and advisory, company secretarial services and Jersey liquidations. The firm is supervised by the JFSC for AML/CFT purposes as a designated non-financial business.

The role

Our client is looking for an experienced compliance practitioner to join us as Compliance Manager. The role is offered on a part-time or flexible basis to begin with, with genuine scope to expand into a full-time senior position as the workload grows.

This is a hands-on role: the successful candidate will own a wide range of matters rather than specialise in any one of them, supporting the Managing Director (who also acts as MLRO and MLCO) and working directly with the wider team rather than through layers of management.

Key responsibilities

Trust Company Business 

Assisting the MLCO in maintaining compliance with the Financial Services

(Jersey) Law 1998, the Codes of Practice for Trust Company Business, and the conditions of the Class O registration

Maintaining the firm's Business Risk Assessment and the Customer Risk Assessments, and reviewing them at appropriate intervals or when triggers arise

Operating the Compliance Monitoring Programme, including periodic file reviews of directorship and secretarial engagements, and reporting findings to the MD

Preparing regulatory notifications to the JFSC (including changes to principal persons, material changes to the business, and breach notifications), and managing the annual return and fee process

Maintaining the outsourcing register and reviewing the firm's third-party arrangements Liaison with the JFSC on routine and ad hoc matters under the MD's supervision 

AML/CFT and Schedule 2 — both businesses

Supporting the MLRO/MLCO in discharging their statutory functions under the Proceeds of Crime (Jersey) Law 1999, the Money Laundering (Jersey) Order 2008, the Sanctions and Asset-Freezing (Jersey) Law 2014, and the JFSC AML/CFT/CPF Handbook

CDD and EDD reviews on new client take-on and on a periodic basis, including review of the team's CDD work on engagements

Operating ongoing sanctions and PEP screening across the client book and documenting the results

Maintaining source of funds and source of wealth evidence on file where required Receiving and considering Internal Suspicion Reports from staff, supporting the MLRO in deciding whether to make external SARs to the JFCU, and maintaining the SAR register

Maintaining the AML/CFT policies and procedures manual and updating it for changes in law, regulation and Handbook guidance

Planning and delivering the annual AML/CFT training programme to staff, and maintaining the training records

Maintaining registers covering breaches, complaints, gifts and hospitality, conflicts of interest and political contributions

Supporting the firm's obligations as a Schedule 2 business supervised by the JFSC, including the periodic compliance return and any thematic information requests Beneficial ownership and statutory filings

Maintaining the beneficial ownership and significant person records for entities under control and ensuring timely filings with the JFSC Registry

Monitoring changes in the Companies (Jersey) Law 1991 and Registry requirements thataffect the firm's obligations

Data protection

Acting as the firm's day-to-day point of contact for data protection matters and maintainingthe Records of Processing Activities under the Data Protection (Jersey) Law 2018

Maintaining privacy notices, retention schedules, processor agreements and the breachregister

Handling Data Subject Access Requests and other rights requests within the statutory timelimits

Managing the firm's annual notification and fee with the Office of the Information Commissioner, and serving as primary liaison with the JOIC

Carrying out Data Protection Impact Assessments where new processing activities or systems require them

Information and cyber security

Maintaining the firm's information security and acceptable use policies and reviewing them annually

Working alongside our outsourced IT provider on access controls, multi-factor authentication, patching, backup, and the firm's Microsoft 365 and Azure environment

Monitoring JFSC cyber security guidance and the firm's response to it, and keeping the cyberrisk assessment current

Coordinating phishing awareness exercises and staff cyber training

Maintaining the incident response plan and the cyber/IT incident register, and leading the response to incidents under the MD's direction

Business continuity and operational resilience

Maintaining the Business Continuity Plan and arranging periodic testing

Maintaining the supplier and key dependency register and reviewing concentration and resilience risk

Other compliance matters

Supporting the firm's compliance with the ICAEW Code of Ethics and the firm's professional body obligations for the accountancy practice, including the firm's annual return and PII renewal

Maintaining the firm's complaints handling procedure and complaints register

Maintaining the whistleblowing arrangements

Maintaining the anti-bribery and anti-facilitation of tax evasion policies

Carrying out regulatory horizon scanning across the JFSC, JOIC, ICAEW and other relevant bodies, and briefing the MD on developments that affect the firm

Preparing quarterly compliance reports for the board and contributing to the firm's annual compliance report

What they are looking for

Essential

Demonstrable compliance experience in a Jersey regulated business — trust company, fund services, accountancy or similar

Strong working knowledge of the Jersey AML/CFT regime and the JFSC Handbook

Familiarity with the Data Protection (Jersey) Law 2018 in a practical setting

Comfortable working unsupervised, prioritising your own workload, and owning matters end-to-end in a small-firm environment

Clear, accurate written communication — comfortable drafting policies, file review notes, board papers and regulatory correspondence

Discretion and sound judgement in handling sensitive client and staff matters

Desirable

ICA Diploma in Compliance, Diploma in AML, ACAMS, STEP, ICSA, or equivalent

qualification, or working towards one

Direct experience supporting an MLRO or MLCO function

Familiarity with the JFSC Registry, beneficial ownership filings and the Companies (Jersey) Law 1991

Awareness of the cyber security expectations placed on small Jersey regulated firms

Experience preparing or reviewing Business Risk Assessments and Compliance Monitoring Programmes