Senior Compliance Manager

Working in partnership to build better businesses.

Triton is an investment firm that believes in engaging with boards, managers and employees to build better businesses.  We are entrepreneurs who invest capital where we can see an opportunity to create long-term value.   
 
We believe Triton is a great place to work and we want our team to be entrepreneurial, enjoy being part of a collective effort, inspire and challenge each other, and to bring an international mindset.

The Role

The focus and purpose of the position is to manage and support the Jersey Compliance Team and reports to the Head of Compliance (based in London). When appointed as a Key Person, a direct reporting line also exists to the respective board of directors, the general partners of the Triton funds and the Jersey Operations Committee (OpCom). The postholder will be required to liaise directly with the JFSC, Jersey FIU, and other regulators as required.

As a Senior Compliance Manager within the Compliance Team, you may be appointed to any of the following Triton Key Person positions, or positions that are provided to our customers under the AML Service Provider guidelines, dependent upon skills, experience and seniority, including the General Partners and Funds, subject to approval by the relevant board and no-objection from the JFSC where required:

• Compliance Officer (“CO”)

• Money Laundering Reporting Officer (“MLRO”)

• AMLSP Money Laundering Reporting Officer (“AMLSP - MLRO”)

Triton Investment Management Services Limited (“TIML”) is a fund services business. Triton Administration (Jersey) Limited (“TAJ”) is a fund services business and a trust company business holding eight classes of trust licences and Addison Nominees Limited (“ANL”) is a trust company business participating member, affiliated to TAJ.

The Senior Compliance Manager is responsible for ensuring that all Triton entities, general partners and funds in Jersey operate in compliance with all respective legislation and regulation.

The role will also include the management and oversight of the completion of other compliance tasks in Jersey including, but not limited to: compliance monitoring / testing, updating regulatory registers, delivering and arranging training, updating the business risk assessment, conducting regulatory reporting, producing and delivering reports to boards / committees, as well as providing guidance to staff on all compliance topics and proving support to the Compliance teams in our other locations.

Some travel to other Triton offices, including London and Luxembourg may be required.

Legal Responsibilities

Whilst appointed to the Jersey Key Person positions, the MLRO/CO and the AMLSP MLRO is responsible for adherence to the relevant primary and secondary legislation, as well as JFSC Codes and Guidance including:

• Financial Services (Jersey) Law 1998.

• Money Laundering (Jersey) Order 2008.

• JFSC AML / CFT / CPF Handbook.

• Trust Company Business Code of Practice (in full).

• Fund Services Business Code of Practice (in full).

• Certified Funds Code of Practice (in full).

• Alternative Investment Funds Code of Practice (relevant sections).

• Guidance Notes issued by the JFSC.

• Legal Notices issued by the Government of Jersey.

• Any other applicable legislation (https://www.jerseyfsc.org/industry/legislation/all-legislation/ & https://www.jerseyfsc.org/industry/financial-crime/amlcftcpf-legislation/).

Regulatory Responsibilities

Whilst appointed to the Jersey Key Person position of Compliance Officer (TCB & FSB Codes of Practice focused):

• Act as principal point of contact for employees on day to day regulatory matters.

• Ensure that a Policy and Procedures Manual covering business compliance with the Codes of Practice is maintained, including checking that the business maintains operations procedures and carrying out appropriate testing of the same to assess the robustness of internal systems and controls and their compliance with the applicable rules.

• Act as the point of contact for the annual regulatory audits with the business’ external auditors.

• Attend regular relevant training to assist with the role and responsibilities.

• Ensure appropriate monitoring of operational performance and managing regulatory and compliance risk including a compliance monitoring programme which:

• Monitor that the internal policies and procedures are being consistently and effectively adhered to;
• Assess and make recommendations for amendments to internal systems and controls as well as policies and procedures to facilitate compliance with the regulatory framework; and
• Promptly action any identified deficiencies where possible and/or raise them to the relevant board of directors and senior management.

• Provide senior management and the boards of directors with regular written Compliance Officer reports in respect of business compliance with the requirements of the FSJL Orders and Codes of Practice.

• Act as the principal point of contact with the JFSC on day to day regulatory matters.

• Ensure that the JFSC is notified if the CO is temporarily unable to fulfil their responsibilities and that an appropriate skilled and experienced alternative is designated.

Support the business to meet their regulatory requirements, including:

• Ensure that an effective corporate governance system is in place to include regular compliance reporting, including as a part of that reporting, advising the relevant board of directors where required on the sufficiency of their corporate governance programme including changes as required when legislative changes occur etc, as well as:

• Checking that clearly defined procedures exist to allow appropriate oversight by the Board of Directors to carry out effective risk management to include:
• a documented assessment of business risks including the ways in which they are monitored and controlled;
• maintenance of accurate and reliable information systems; and
• timely and appropriate management reporting.

• Ensure that such systems and controls are reviewed periodically to ensure effectiveness.

• Ensure that adequate business resumption, disaster recovery and contingency arrangements are put in place and test their adequacy at appropriate intervals.

• Ensure Incidents and Breaches Registers are maintained and updated.

• Ensuring that adequate records are maintained covering business transactions, financial position, internal organisation, risk management systems, board or management minutes and the relationship between regulated entities.

• Ensure that a Complaints policy is established and maintained as required.

• Ensure that the business gives adequate consideration to data security, data protection and other record keeping requirements.

• Ensure that adequate insurance is maintained by the business, including periodic reviews of insurance arrangements.

• Ensure necessary reporting and notifications as well as licence renewals with the relevant authorities are maintained.

• Ensure regulatory training is gained by all relevant individuals, as and when changes occur, to relevant legislation and guidance.

• Ensure that all relevant employees undertake annual Continued Professional Development as required by the Codes of Practice and AML/CFT/CPF Handbook and that appropriate records are maintained.

Whilst appointed to Key Person positions of MLRO (AML Handbook focused on Suspicious Activity Reporting and training). Follow all relevant legislation and regulatory guidance, specifically in relation to the receipt, review and externalisation of SARs including:

• Receive and consider all internal suspicious activity reports (“SARs”) directly from employees as soon as practicable

• Provide an acknowledgment to the submitter of each SAR.

• Externalise SARs to the relevant authorities as and when necessary.

• Review and record all internal and external SARs in a register, including all decision-making processes and enquiries, with all supporting documentation being available on a timely basis.

• Consider the time taken between the matter coming to the employee’s attention and the submission of the SAR, together with the appropriateness of the content of the SAR.

• Attend regular relevant training to assist with the role and responsibilities.

• Provide regular reports to the boards of directors which include the typical time taken to process a SAR, through to the decision or not to externalise, as well as advising the number of SARs that have exceeded the typical timeframe.

• Maintains a record of all requests for information from law enforcement authorities and records relating to all internal and external SARs.

• Manages relationships effectively post disclosure to avoid tipping off any external parties.

• Act as the liaison point with the Commission and the Jersey FIU and in any other external enquiries in relation to money laundering or financing of terrorism or proliferation financing.

• As MLRO, appoint Deputy MLROs within the business as required, record details of such Deputy MLROs and provide support and oversee their work including determining that SARs are being handled in an appropriate and consistent manner.

• Ensure that in the event that the position of MLRO is expected to fall vacant, to comply with the statutory requirement to have an individual appointed to the office of MLRO at all times, take action to appoint a member of the Board (or other appropriate member of senior management) to the position on a temporary basis.

Also:

• Ensure robust policies and procedures, systems and controls are incorporated within the business for identifying potential SARs and facilitating their reporting to the MLRO.

• Ensure staff are adequately trained in suspicious activity and are aware of their responsibilities to file a SAR with the MLRO.

Whilst appointed to the positions of AMLSP MLRO, follow all relevant legislation and regulatory guidance as well as section 18 of the AML/CFT/CPF Handbook, together with the guidance in the above sections relating to the key person position of MLRO.

Other Responsibilities

• At all times ensure that all Triton entities, general partners and funds operate in compliance with all respective legislation and regulation.

• Support the Jersey Compliance team with their responsibilities.

• Ensure the relevant boards of directors are provided with regular and comprehensive compliance reporting.

• Write and keep up-to-date Jersey Compliance policies and procedures.

• Maintain awareness of the changing Jersey regulatory environment, keeping up to date with requirements by reading consultation papers and ensuring the business reacts to new requirements, for example beneficial ownership registers and national risk assessment reporting.

• Complete ad-hoc requests from investors including the completion of due diligence questionnaires.

• Complete tasks and projects to support Compliance and the business in general.

The Candidate Profile

• In terms of the experience, skills and competencies required for the position, we would highlight the following:

• Be able to operate independently.

• Have the required skills and experience including holding an appropriate Compliance related qualification.

• Have appropriate gravitas and influence to ensure that senior management and the boards of directors react to, and determine whether to act upon recommendations, (unfettered access is provided to all business areas, support departments and information necessary to properly discharge responsibilities, including senior management and the Board of Directors or equivalent).

• Have confidence in engaging and potentially challenging senior management and the boards of directors.

• Be able to manage time effectively to discharge properly the responsibilities of the function for all appointments.

Personal Attributes

• Ambitious, driven and high energy.

• A good team player and collaborative.

• Humble and honest with the ability and willingness to learn from mistakes. Client focused and committed to delivery.

Triton is an equal opportunity employer.  We recognise that diversity is key to our continued success, and strive to maintain a fair and equitable recruitment process for all applicants.