MLRO and MLCO Guernsey

Location   Guernsey

Position    MLRO and MLCO Guernsey

Purpose of Role

The purpose of the role is to assist and support the business in achieving its strategic, financial and operational goals in line with the local regulatory and legal framework, to promote and maintain a positive compliance culture and protect the firm from compliance, regulatory, financial crime, reputational and operational risk within the business. To support the Head of Guernsey Compliance in the day to day running of the Guernsey Compliance function with a primary focus on Funds business. To manage compliance team members as required from time to time.

Key Accountabilities

The role holder will act as the Money Laundering Compliance Officer and Money Laundering Reporting Officer to the business. In addition, the role holder will provide a point of contact for compliance matters arising within ZFMGL in support of the Head of Compliance Guernsey. This is a Key Person position and includes the following regulatory obligations:

    • Responsibility for supporting compliance requests of ZFMGL and their client entities, ensuring their regulatory responsibilities are fulfilled.
    • Act as the Money Laundering Reporting Officer (MLRO) for the business.
    • Act as the Money Laundering Compliance Officer (MLCO) for the business.
    • Be a key contributor to maintaining a positive compliance culture within the business by being approachable, commercially minded, and striving to identify solutions.
    • Providing training to all members of the business on compliance related matters and to ensure demonstrable understanding of regulatory obligations including AML and CFT obligations.
    • Input to the Compliance Monitoring Plan (CMP) arrangements and its testing of the effectiveness of policies, procedures and controls and providing feedback on the same to the Board.
    • Support the monitoring of policies, procedures and internal systems and controls to ensure they are maintained in line with legislation and regulations (including TISE), Zedra Group Business Principles and industry best practice, making recommendations for amendments where necessary.
    • Drafting new or making amendments to existing policies and procedures in a timely manner, as required.
    • Where appropriate in support to the Compliance Officer, promptly instigating action to remedy any compliance or control deficiencies.
    • Ensure that the business has an open, strong and effective relationship with the Guernsey Financial Services Commission (‘GFSC’) and TISE.
    • Supporting the Head of Compliance Guernsey to ensure that policies, the CMP and the Business Risk Assessment are reviewed and presented to Board at a minimum annually, but more frequently when necessary.
    • To receive internal Suspicious Activity Reports (‘SAR’), acknowledge receipt, investigate and, where appropriate externalize to the Financial Intelligence Unit (‘FIU’), ensuring that the SAR register is kept up to date, there is recorded evidence of decisions made and, where a SAR has been externalized appropriate action has been taken to ensure that funds cannot be released from the account without having sought consent from the FIU.
    • To monitor the FIU system THEMIS to ensure that communications e.g. Sanctions and Financial Liaison Notices are reviewed and actioned where necessary.
    • To ensure that court orders e.g. production orders are actioned within the deadline.

The role holder will be responsible for ensuring appropriate monitoring of operational performances and managing regulatory and compliance risk within the registered person, which includes:

    • Preparing reports to the board in relation to regulatory matters, including ML/TF matters and issues requiring the Boards attention.
    • Providing direction on policies and procedures, including financial crime policies and procedures and those in relation to financial sanctions.
    • Maintaining an effective working relationship with the Guernsey Financial Services Commission and the Guernsey Financial Intelligence Unit as well as other relevant competent authorities, responding promptly to requests for information made.
    • Providing an effective AML/CFT and regulatory advisory service to the business.
    • Overseeing compliance aspects of the annual audit, internal audits, and regulatory visits etc.
    • Reviewing new business prior to take-on.

Knowledge and Experience

Professional and Technical Experience

    • Proven track record in the identification and prevention of money laundering and funding of terrorism, with some experience in compliance oversight of the administration of Funds structures.
    • Detailed technical knowledge of Anti Money Laundering, Countering the Financing of Terrorism and all related financial crime legislation, codes and regulatory guidance as well as industry best practice is essential.
    • Knowledge of local funds services business laws and regulation are preferred.
    • Ability to deal with complex structures where regulatory and policy interpretation is required.
    • A good understanding of ZEDRA's AML/CFT risk appetite and business practices.
    • The role holder must have the technical knowledge and ability to build credibility with all employees.
    • Experience of risk and compliance within Financial Services and a solid understanding of the Wealth Management industry sector and the associated client needs.

Personal Attributes

    • Ability to work within a team environment.
    • Ability to articulate succinctly and efficiently deal with a wide range of business issues.
    • Ability to investigate and challenge in a positive and non-confrontational manner.
    • Seek to improve and develop existing working practices.
    • Share best practices, coach and motivate others to succeed.
    • Excellent organizational skills and attention to detail.
    • Good communicator (verbal and written) with the ability to explain technical detail.
    • Strong relationship building skills.
    • Self-starter with the ability to work on own initiative.
    • To be based in Guernsey.

Language Skills

The right candidate will be fluent in English, with strong written and oral communication skills. Strong written and verbal communication skills are a critical requirement of the position.

Academic and Professional Qualifications

The right candidate will have an established background at a senior level in financial services regulation and hold relevant professional qualifications.


If you are interested in joining our dynamic and driven international team, please email your CV and covering letter specifying your desired role to [email protected]