AML Director, Capital Markets
Location: London, United Kingdom
Schedule: 37.5 hours per week
Work arrangement: Hybrid
Vacancy type: Permanent
Job Summary
The AML Director will serve as a Board Director for a portfolio of Special Purpose Vehicles ("SPVs") administered by the CSC UK Capital Markets team (the “Company”) that are registered with the FCA as Annex 1.
The role holder will be appointed to the boards of multiple SPVs and will be responsible for providing senior management oversight of anti-money laundering, counter-terrorist financing and sanctions compliance arrangements in accordance with applicable regulatory requirements.
As the SPVs are administered through a corporate services model and do not employ staff directly, the AML Director will focus on governance, oversight, challenge and accountability for the AML framework operated on behalf of the SPVs. The AML Director will work closely with the SPV's Nominated Officer function and fellow board directors to ensure that AML obligations are met and financial crime risks are effectively managed.
In addition to undertaking AML Director appointments, the individual will support AML-related remediation initiatives, regulatory projects and financial crime governance activities across the Company's SPV and Capital Markets business.
Key Responsibilities
AML Director Appointments
- Act as AML Director for a portfolio of approximately 10-15 SPVs.
- Serve as a director of appointed SPVs and participate fully in Board deliberations and decision-making.
- Maintain oversight of each SPV's AML, sanctions and financial crime risk framework.
- Ensure AML governance arrangements remain appropriate having regard to the nature, scale and complexity of the relevant SPV.
- Exercise effective challenge and independent judgement in respect of AML and financial crime matters presented to the Board of the relevant SPV.
- Ensure Board decisions appropriately consider AML and financial crime risks.
- Review and approve AML policies, risk assessments and other governance documents where required for each of the SPV’s.
- Escalate material AML concerns, regulatory issues or control weaknesses to the Board and relevant internal stakeholders.
- Act as a director on the UK Capital Markets operating entity
- Ensure the Company’s Board decisions appropriately consider AML and financial crime risks.
Oversight of the Nominated Officer Function
- Work closely with the Company's appointed Nominated Officer(s) supporting the SPV portfolio.
- Receive periodic reporting regarding suspicious activity reporting, investigations and financial crime risks.
- Ensure suspicious activity reporting arrangements remain effective and appropriately governed.
- Provide oversight and challenge of AML reporting and financial crime escalations.
- Ensure the Nominated Officer function has adequate support, resources and access to Board-level decision makers.
- Participate in discussions relating to complex AML matters, high-risk relationships and material escalations.
Client and SPV Governance
- Attend Board meetings and governance forums for assigned SPVs.
- Review and challenge reports received from outsourced providers, trustees, servicers, cash managers and other transaction parties.
- Review and/or prepare AML-related Board papers and governance materials.
- Ensure AML considerations are embedded within the overall governance framework of the SPV.
- Support the maintenance of robust governance records and Board documentation.
Financial Crime Risk Oversight
- Review entity-level AML risk assessments.
- Consider emerging financial crime risks and regulatory developments relevant to SPV structures and capital markets transactions.
- Monitor the effectiveness of AML controls and supporting governance arrangements.
- Support implementation of risk mitigation measures where required.
- Ensure AML and sanctions issues are appropriately assessed and documented.
Additional Expectations
While acting as AML Director will be the primary focus of the role, the successful candidate will also be expected to support broader AML and compliance initiatives across the SPV business.
AML Remediation Projects
- Lead or support AML remediation programmes arising from internal reviews, independent testing, client reviews or regulatory feedback.
- Assist with gap analysis exercises and development of remediation plans.
- Monitor implementation and completion of agreed corrective actions.
- Support preparation of management and Board reporting relating to remediation activities.
AML Framework Development
- Contribute to the ongoing enhancement of AML policies, procedures and governance frameworks.
- Assist with periodic reviews of AML risk assessment methodologies.
- Support the development of financial crime governance standards across the SPV business.
- Participate in the implementation of regulatory change requirements.
AML Advisory and Subject Matter Expertise
- Provide AML and financial crime advice to colleagues, directors and client teams.
- Support new business reviews and onboarding of prospective structures from an AML perspective.
- Assist with client due diligence, risk assessments and governance reviews.
- Provide technical interpretation of AML regulations and industry guidance.
- Act as a subject matter expert for SPV-related AML matters.
Strategic Projects
- Participate in compliance, governance and operational improvement initiatives.
- Support regulatory readiness programmes and internal governance reviews.
- Assist with development of best practice standards across the Company's corporate services business.
Success Measures
The successful candidate will:
- Effectively discharge AML Director responsibilities across a portfolio of SPVs.
- Deliver robust AML governance and Board oversight.
- Support the effective operation of the Company's Nominated Officer framework.
- Successfully contribute to AML remediation and enhancement initiatives.
- Provide credible AML expertise to clients, directors and internal stakeholders.
- Strengthen the Company's overall AML governance and financial crime framework across its SPV business.
Experience and Qualifications
Essential
- Significant experience in AML, financial crime compliance or regulatory compliance.
- Previous experience as an MLRO, Nominated Officer, AML Director, Head of Financial Crime, Compliance Director or similar senior role.
- Previous Board Director experience.
- Strong understanding of UK AML legislation and financial crime regulatory requirements.
- Experience presenting and reporting to Boards and senior governance committees.
- Strong stakeholder management and governance experience.
Preferred
- ICA Diploma, CAMS or equivalent AML qualification.
- Experience working with SPVs, structured finance transactions, securitisation vehicles, trustee services or corporate services businesses.
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