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

Client Compliance Officer

Summary

This Client Compliance Officer role is to act as a nominated MLCO/AMLCO / MLRO/AMLRO for several of the Jersey Non-Collective Investment funds/Jersey Private Funds and Schedule 2 entities to which Apex provides services. The Client Compliance Officer will have direct access to the boards of the relevant Registered/Supervised Persons, and unfettered access to all business lines, support departments and necessary information. The Client Compliance Officer will report to the Head of Client Compliance in Jersey.

The role & Key Responsibilities

The Client Compliance Officer will fulfil the role of MLCO/AMLCO / MLRO/AMLRO for a number of Non- Collective Investment Funds and Schedule 2 entities. Where the role is supported by resources, this role may include line management responsibility.

Key responsibilities can be summarised as follows:

• Monitoring compliance of the relevant Registered/Supervised Person’s compliance with legislation in Jersey relating to money laundering and financing of terrorism and the AML/CFT/CPT Codes of Practice issued under the Supervisory Bodies Law by undertaking a Compliance Monitoring Program ensuring that findings are escalated and remediated to conclusion;
• Ensuring that there are adequate procedures for monitoring compliance with, and testing the effectiveness of policies and procedures;
• Ensuring that there are adequate procedures for monitoring and testing the effectiveness of measures to raise awareness and training that are commensurate with the AML/CFT/CPT risks faced;
• Monitoring whether the enactments in Jersey relating to Money Laundering and the Financing of Terrorism and AML/CFT/ CPT Codes of Practice are being complied with;
• Monitoring and testing compliance with systems and controls (including policies and procedures) in place to prevent and detect money laundering and financing of terrorism; apexgroup.com 3
• Reporting periodically as appropriate to the boards of the Registered/Supervised Persons on compliance with the Administrator’s and Registered/Supervised Persons, systems and controls (including policies and procedures) and issues that need to be brought to their attention;
• Receive and consider internal SARs in accordance with internal reporting procedures;
• Make timely disclosures to the Financial Intelligence Unit (FIU) where necessary;
• Maintain a record of all requests for information from law enforcement authorities and records relating to all internal and external SARS;
• Advise in the management of relationships effectively post any disclosure to avoid tipping off;
• Act as the liaison point with the Jersey Financial Services Commission (JFSC) and the FIU and in any other external enquiries in relation to money laundering or financing of terrorism;
• Maintain a Register of Suspicious Activity Reports;
• Where a deputy MLRO is appointed, keep a record of all deputy MLROs;
• Provide support to, and routinely monitor the performance of each deputy MLRO and consider and determine 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.

Other Responsibilities

• Maintain appropriate independence;
• Initiate Themed Compliance Reviews as/when required;
• Keep abreast of the 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 as/when required;
• Ensure that your required level of CPD is undertaken each year; and
• assist with other duties to support Jersey’s Head of Compliance Solutions as may be necessary from time to time.

Skills Required

• You will have substantial finance sector experience with an excellent understanding of the Jersey regulatory environment and preferably (although not essential) have previously held Key Roles;
• sufficient experience and skills which include holding an appropriate Table 4 qualification (as determined 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 and Countering of Proliferation Financing;
• A sound knowledge of the Financial Services (Jersey) Law 1998, any orders issued under the Law;
• A sound knowledge of other regulatory and legislative requirements applicable to the business undertaken by the Registered/Supervised Persons;
• Full awareness of your own obligations and those of the Registered/Supervised Persons under the laws mentioned above as well as the Terrorism Law, the Directions Law, Terrorist Sanctions Measures etc.;
• Excellent time-management skills, being self-motivated, pro-active, and capable of prioritizing workloads as required;
• Excellent communication skills with the ability to effectively communicate with boards and colleagues;
• A good working knowledge of Microsoft office products, in particular Outlook, Word and Excel;
• Attention to detail;
• Good report writing skills;

Disclaimer: Unsolicited CVs sent to Apex (Talent Acquisition Team or Hiring Managers) by recruitment agencies will not be accepted for this position. Apex operates a direct souring model and where agency assistance is required, the Talent Acquisition team will engage directly with our exclusive recruitment partners.