AFEX is committed to the highest standards of Anti-Money Laundering (AML) and Anti-Financial Crime including Anti-Bribery and Corruption, Counter Terrorism Financing (CTF), Anti-Fraud and other punishable criminal acts. The members of the Management Board and all employees are required to adhere to these standards to protect AFEX and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.
The Compliance department, under the Risk & Compliance Department, ensures compliance with all applicable laws, rules, regulations, and with Company policies by establishing risk-based policies and procedures. AFEX’s business operations are organized into three business units or regions; the Americas, Europe, the Middle East and Africa (EMEA), and Asia Pacific.
We are currently hiring for a Compliance Manager, Integrated Solutions in our Woodland Hills office.
The Compliance Manager - Integrated Solutions (“Compliance Manager - InS”) is a member of the Global Compliance Team. The Compliance Manager - InS provides subject matter expertise on significant and strategic business initiatives and on-going operations, including complex processes, policies and procedures, etc., relating to various programs, including but not limited to, AML/CTF Compliance, KYC, Sanctions, and Privacy for AFEX’s Integrated Solutions (“InS”) globally. This role establishes, develops and maintains a Compliance Framework designed to support the Company’s strategic objectives for InS. The Compliance Manager, along with the regional Compliance teams proactively assist the Business, Customer Engagement/IT and other functional areas with each InS opportunity and engagement while measuring, monitoring and managing compliance risks.
In executing their duties, the Compliance Manager – InS should act as a Brand Ambassador for AFEX, to act in a way that promotes AFEX’s Vision: A trusted business partner. All actions and interactions both internally and externally should be executed to underpin and uphold the AFEX core values:
- Trust: Our aim is to build a long-term relationship, becoming your trusted partner. We earn trust by delivering on our commitments and putting the needs of our customers and colleagues first.
- Expertise: We strive to be the best in our field; through our dedication to continually learn and excel, we’ll deliver strategically adept solutions that work for you.
- Value: We constantly challenge ourselves to find the best ways to deliver value to our clients and each other, providing personalized services that enhance our customer’s business.
Day-to-Day Oversight of InS Opportunities and Engagements (50%)
- The Compliance Manager - InS supports the Compliance Director – Integrated Solutions to assess business opportunities, provide advice on the design, implementation, and operation of processes and systems to mitigate compliance risk with each business engagement.
- Responsible for providing compliance support for all Integrated Solutions activities, including the review of sales opportunities and throughout the implementation of InS opportunities.
- Responsible to provide compliance-related advice and guidance to Integrated Solutions Team, Product, Customer Engagement and other functional areas.
- Assist with providing Integrated Solutions team and other functional areas compliance training pertaining to integrated solutions, partnerships, etc.
- Develops, initiates, maintains, and revises policies and procedures for the general operation of the Global Compliance Program for Integrated Solutions and its related activities to prevent illegal, unethical, or improper conduct. Manages day-to-day operation of the Program.
- Supports the implementation of the strategic vision (maturity, efficiency, streamlined processes) for InS opportunities/engagements by encouraging operational processes that are aligned to the Company's focus on scalability and efficiency.
- Participates during any sales discovery meeting, client engagement discussions, client engagement document review, opportunities discussion, onsite visit, stakeholder client engagement meeting, monthly/quarterly regional InS meeting.
- Responsible to assess InS opportunities and approve a Risk Management Plan, if applicable, and any other documentation required to document the business opportunity, controls to ensure the applicable AFEX legal entity will meet its regulatory obligations and the evidence that the opportunity’s residual risks are within the Company’s risk appetite.
- Reviews any InS-related document to provide feedback/approval for business engagements while ensuring the applicable regional Compliance Director has understood all relevant inherent money laundering risk factors (risk profile), the nature of mitigating controls, both from a design and operating effectiveness standpoint.
- Works effectively as part of a larger team to drive projects and deliverables.
- Provides insight regarding customer/partnership reputation and AML risk issues including, but not limited to, AML risks as they apply to products and services, customer onboarding, customer account closures, the application of the AML Policy, and the implementation of Line of Business for AML internal controls including customer identification, CDD, customer risk rating and quality assurance programs.
- Assists in building relationships and trust of front line and back office staff to develop and instill a culture that supports AML risk mitigation
- Works closely with the global and regional compliance teams to provide guidance and help resolve any control weaknesses, or any process modification needed to support an InS opportunity.
- Collaborates with relevant managers to implement and understand the importance of clear and concise AML policies and procedures.
- Partners with Global Compliance to share information, policies, and best practices to ensure operational excellence.
- Pro-actively assists in solving issues and delivers effective solutions in an efficient manner and escalating complex matters to the Chief Risk Officer or Global Compliance Officer.
- Prepares compliance InS risk assessments.
- Provides support to ensure controls are adequate to address and mitigate the AML risks identified in the risk assessment process and address emerging risks with InS or any other technology-based product or service.
- Collaborates with other departments (e.g., Risk Management, Internal Audit, Human Resources, etc.) to direct compliance issues to appropriate existing channels for investigation and resolution. Consults with the external attorneys as needed to resolve difficult legal compliance issues.
- Responds to alleged violations of rules, regulations, policies, procedures, and Code of Conduct by evaluating or recommending the initiation of investigative procedures. Develops and oversees a system for uniform handling of such violations.
- Acts as an independent review and evaluation body to ensure that compliance issues/concerns within integrated solutions are being appropriately evaluated, investigated and resolved.
- Monitors, and as necessary, coordinates compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends.
- Identifies potential areas of compliance vulnerability and risk; develops/implements corrective action plans for resolution of problematic issues
- Provides reports on a regular basis, and as directed or requested, to keep the Risk Oversight Committee of the Board and senior management informed of the operation and progress of compliance efforts.
- Ensures proper reporting of violations or potential violations to duly authorized enforcement agencies as appropriate and/or required.
- Institutes and maintains an effective compliance communication program for the region, including promoting (a) use of the Compliance Hotline; (b) heightened awareness of Code of Conduct, and (c) understanding of new and existing compliance issues and related policies and procedures.
- Monitors the performance of the Compliance Program and relates activities on a continuing basis, taking appropriate steps to improve its effectiveness.
AML Governance (25%)
- Maintain a current, thorough understanding of money laundering and terrorist financing issues, including policies, procedures, regulations, industry best practices, criminal activities and developing trends. Analyze the implications of emerging issues on enterprise policies and procedures.
- Escalate potential issues regarding processes and operations that support InS opportunities/engagements to the Global Compliance Officer, Global Risk Manager and Chief Risk Officer.
- Serve as a subject matter expert and advise team members and GRC colleagues on current AML/ATF and fraud issues and trends to effectively apply controls and tools in mitigating operational risks.
Team Efficiency and Effectiveness (25%)
- Provide timely and relevant communication and operational training and coaching to team members. Identify and deliver additional training as changes to enterprise policies and programs are implemented.
- Set appropriate context and establish prescribed limits for team members, including maintaining an effective framework of policies and procedures. Recommend changes where required.
- Assist the Global Compliance Team in applying performance management system.
- Review progress on team projects and initiatives and regularly communicate status to the GRC Functional Managers and Chief Risk Officer.
- This role has sufficient authority and autonomy to implement a global compliance program designed to support InS opportunities globally, as well as the ability to take actions – along with the regional Compliance Director or the Compliance Director – InS – to address and mitigate risks that might arise from InS engagements and to file any necessary regulatory reports.
- This role has sufficient authority to approve any InS opportunity.
- This role has the authority to effectuate change and exercise independent judgment globally. Additionally, this role is empowered to report compliance matters directly to the Compliance Oversight Committee, as well as the Risk Oversight Committee.
Reports to Compliance Director – Integrated Solutions.
Adhere to the Compliance Program of each jurisdiction.
Authorized to act on behalf of Compliance with regard to ensuring Company compliance with the relevant government regulatory and corporate governance obligations.
- Minimum of five years of proven AML Compliance and Region/Line of Business experience within a financial institution.
- Very strong relationship building, networking, managerial, interpersonal, and communication skills required.
- Strong analytical, organizational and planning skills required.
- Deep knowledge of AML risks including those imposed by client composition, markets and geographies served, and products and services offered, etc.
- Ability to work in a highly regulated, demanding and changing environment.
- Proven ability to develop and foster strong interpersonal relationships and to maintain effective cross-functional teams throughout the organization. Demonstrated ability to effectively represent Compliance with industry peers and in client-facing situations is required.
- Experience managing the delivery of projects ability to work with multiple time sensitive projects while ensuring success.
- Proven ability to exercise judgment, pursue initiatives and implement changes necessary to align functional area with strategic/long-term goals of the Compliance Department is required.
- Significant experience with reviewing, evaluating, designing and implementing key compliance functions, including risk-based monitoring programs, user manuals and/or personnel training is required.
- Successful supervisory or management skills in a variety of settings.
- Extensive knowledge of relevant regulatory and corporate governance rules and regulations.
- Demonstrate a keen attention to detail in investigation, analysis, and writing.
- Commitment to goals, demonstrates excellent professionalism and operational leadership skills.
- Ability to work well with and collaborate with others.
- Understanding of legal, regulatory, commercial operations, and credit functions.
- Constantly curious, seeks and implements new solutions, novel workflows.
AFEX is committed to offer equal employment opportunities to all employees and applicants for employment, without regard to their race, color, religion, gender, sexual orientation, gender identity or expression, national origin, age, disability, genetic information or military or veteran status. AFEX complies with all applicable laws governing discrimination and harassment in employment in every location and jurisdiction in which the Company has facilities. This policy applies to all terms and conditions of employment, including recruiting, hiring, placement, promotion, termination, layoff, recall, transfer, leave of absence, compensation and training.
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