The Apex Group was established in Bermuda in 2003 and is now one of the world’s largest fund administration and middle office solutions providers.

Our business is unique in its ability to reach globally, service locally and provide cross-jurisdictional services. With our clients at the heart of everything we do, our hard-working team has successfully delivered on an unprecedented growth and transformation journey, and we are now represented by over circa 13,000 employees across 112 offices worldwide.Your career with us should reflect your energy and passion.

That’s why, at Apex Group, we will do more than simply ‘empower’ you. We will work to supercharge your unique skills and experience.

Take the lead and we’ll give you the support you need to be at the top of your game. And we offer you the freedom to be a positive disrupter and turn big ideas into bold, industry-changing realities.

For our business, for clients, and for you

The role
The role is to act as the nominated Money Laundering Reporting Officer (‘MLRO) for Apex Jersey and all associated entities (the “Apex regulated entities”) and to manage the Financial Crime Prevention (“FCP”) Function in Jersey.
The role holder will have direct access to the boards of the relevant registered persons and have unfettered access to all business lines, support departments and necessary information.
The MLRO will report to the Jersey Head of Compliance

Key responsibilities

The role holder will fulfil the key person role of MLRO for the Apex regulated entities. Where the role is supported by resources, this role will include line management responsibility.

Key responsibilities can be summarised as follows:

Money Laundering Reporting Officer

• Receipt and consideration of internal SARs in accordance with internal reporting procedures;
• Making timely disclosures to the Joint Financial Crimes Unit where necessary;
• Maintaining a record of all requests for information from law enforcement authorities and records relating to all internal and external SARS;
• Managing relationships effectively post any disclosure to avoid tipping off;
• To act as the liaison point with the Commission, the JFCU and in any other external enquiries in relation to money laundering or financing of terrorism;
• Maintaining a Register of Suspicious Activity Reports;
• Where a deputy MLRO is appointed, keeping a record of all deputy MLRO’s;
• Providing support to, and routinely monitoring the performance of each deputy MLRO, including Consideration and determination that any SARS are being handled in an appropriate and consistent manner by reviewing samples of records containing SARS and supporting documentation and reviewing the decisions and basis for decisions taken in deciding whether to make an external SAR;
• Ensure adequate training is provided to all staff, including the provision of new joiner training, in respect of the prevention, detection and reporting of money laundering, terrorist financing and suspicious activity;
• Provide MLRO advice to the Business as and when required.
• While performing the MLRO responsibilities any potential areas of AML/CFT/CPF vulnerability and risk which are discovered must be reported so that development of corrective plans are instigated;
• Ensure Apex’s money laundering reporting policies and procedures reflect the current AML/CFT/CPF regulatory and legislative requirements;
• Implement and support group’s money laundering reporting initiatives;
• In so far as Risk Escalation Forms related to entities/clients included in the SAR register, these should be reviewed and commented on;
• Provide money laundering reporting support to Compliance team members conducting daily PEP, Sanction, ML and TF screening

Other Responsibilities

• Review sanctions policy and procedures to ensure they remain fit for purpose and are updated at least annually or on a trigger event;
• Ensure training is provided on sanction matters and ensure all senior managers/staff members are aware of their responsibilities for adhering to the sanctions regime;
• Provide support to the client team in relation to any sanction queries/matters;
• Assist the business with any reporting requirements as and when necessary;
• Provide regular reports to the Board as appropriate;
• Work with the Boards’, Senior Management and MLCO in respect of completing Risk Assessments;
• Keep abreast of regulatory developments/requirements in relation to Sanctions.
• Review of transactions connected to jurisdictions subject to sanction / embargo;
• Act as the Jersey Bribery Reporting Officer, as required by the Apex Group Anti Bribery & Corruption Policy.
• Working on several projects/tests at any one time;
• Undertake Themed Compliance Reviews;
• Keep abreast of changing regulatory environment, assess, and recommend amendments to, internal systems and controls as well as policies and procedures to facilitate compliance with the regulatory framework;
• Respond to enquiries from auditors or other service providers;
• Assist the client facing and other support teams with general compliance queries including AML queries;
• Assist with amendments required to policies and procedures including as part of the horizon scanning process;
• Maintain appropriate independence, in particular from customer-facing, business development and system and control development roles;
• Ensure that your required level of CPD is undertaken each year; and
• Assist with other duties to support the Jersey CLCO as may be necessary from time to time including ad-hoc projects undertaken by the Compliance team in response to regulatory changes, changes within the group or internal findings from monitoring and testing.

Skills / Experience

• You have substantial finance sector experience and excellent understanding of and experience with performing AML/CFT/CPF roles within a regulated financial services business and will have:
• Sufficient experience and skills which includes, holding an appropriate (as determine by the registered person) AML or other professional qualification or be studying towards such a qualification;
• A sound knowledge of the Jersey Anti-Money Laundering legislation and any orders issued under those laws;
• A sound knowledge of The Handbook for the Prevention and Detection of Money Laundering and the Financing of Terrorism;
• Full awareness of your own obligations and those of the relevant persons under the laws mentioned above as well as the Terrorism Law, the Directions Law, Terrorist Sanctions Measures;
• Knowledge of the Financial Services (Jersey) Law 1998, any orders issued under the Law;
• Knowledge of the Code of Practice for Trust Company Business;
• Knowledge of the Code of Practice for Fund Services Business;
• Knowledge of the Handbook for the Prevention and Detection of Money Laundering and the Financing of Terrorism;
• Leadership ability with excellent communication skills. You are self-motivated and capable of prioritising workloads as required;
• Excellent communication skills
• Have the flexibility and adaptability to undertake a variety of tasks at short notice if required;
• Good working knowledge of Microsoft products, in particular Outlook, Word and Excel as well as having the capability to quickly assimilate working with Apex’s key databases some of which are bespoke.