Head of Compliance & Risk Manager (Fixed Term Contract)
Business Unit:Compliance, Risk and Internal Audit
This is a senior interim role for Russell Investments France SAS (“RIF”). RIF is regulated by the Autorité des Marchés Financiers (“AMF”).
The purpose of this role is twofold:
Acting as interim RCCI for RIF. The primary activities of the RCCI are the maintenance and monitoring of RIF’s internal control plan, provision of regulatory advice in respect of existing and emerging regulation, provision of regulatory training, regulatory reporting, primary liaison with the AMF and ensuring that regulatory policies, procedures and guidance are in place and kept up to date. Working as an experienced resource with dual reporting to the Director, EMEA Compliance located in London and the President of RIF.
Undertaking the role of Risk Manager responsible for the organisation, development and oversight of RIF’s risk management framework. Working in close collaboration with Russell Investments’ global Risk Management team to receive and assess periodic risk reporting. Maintaining RIF’s incidents database and supporting RIF’s associates in the management of events and their remediation. Undertaking due diligence on third-party delegates as part of RIF’s risk management activities.
This role is a 12 month fixed term contract.
The candidate will need to speak French and English (fluent preferred).
The responsibilities of the individual in this position include:
Helping to maintain a risk-aware compliance culture.
Being an active representative with industry bodies such as Association Française de la Gestion Financière, AMF and any other compliance working group, in order to discuss new issues in the industry from a regulatory perspective, which may have an impact on RIF’s business and on Russell Investment’s business more generally.
Regulatory Strategy/ risk assessment
Maintenance of a regulatory risk assessment for RIF (internal control plan) to underpin and prioritise the activities of the compliance advisory and monitoring components of the role.
External Regulatory Communications
Primary contact and liaison person for the AMF and external auditors but, as necessary, in conjunction with the President of RIF and the Director, EMEA Compliance (as necessary).
Senior Management Reporting
Responsibility for the creation and delivery (by attendance as necessary) of comprehensive regulatory and risk reports to:
The President of RIF
RIF’s governing body
Maintaining awareness of regulatory developments and communicating these to others as necessary.
Contributing to impact analysis of such developments and working alongside others to contribute to implementation activities designed to respond to regulatory developments. This includes interactions with delegates to ensure continued compliance by those delegates with RIF’s regulatory policies and procedures.
Developing and implementing a regulatory framework comprising of:
Maintenance of regulatory policies, procedures and guidance (including associated business operating procedures).
Provision of regulatory advice on all day to day business matters as necessary including advice on new and amended services and products.
Provision of regulatory training both planned and ad-hoc.
Approval and Monitoring of Delegated Activities
Monitoring and oversight of delegates (third-parties and intra-group) both in terms of initial on-boarding and on-going oversight activities.
Being involved in the formal approval of delegate appointments.
Working with other functions to ensure robustness of governance arrangements relating to outsourcing and ensuring that for each outsource service provider, the arrangements meet the AMF’s outsourcing requirements.
Performing monitoring and oversight reviews of delegates (third-parties and intra-group). On-site this may involve travelling both in-state and international.
Recording outcomes of oversight reviews and presenting findings in accordance with senior management reporting requirements.
Developing, documenting and delivering a robust risk-based compliance monitoring program covering RIF’s activities to include on-going guideline surveillance, monitoring and one-off themed investigations as may be required from the risk assessment process and RIF’s internal control plan.
Ensuring reported complaints are recorded and handled in a timely and robust manner and in accordance with applicable regulatory requirements.
Responsibility for the maintainence of regulatory breaches registers.
Working with contributing parties to complete root cause analysis and contributing to processes to mitigate breach reoccurance.
Ensuring appropriate escalation of breaches in accordnace with internal policy.
Lifecycle of funds
Working with the EMEA Solutions team and RIF associates to contribute a ‘regulatory voice’ in the early stages of new product/service development.
Drafting of regulatory documents (KIID, prospectus and regulation for the saving fund) in respect of amendments.
Ensuring validation of such amendments with the relevant custodian and AMF, if necessary.
Being the active risk representative for France with both the EMEA and the Seattle Investment Risk team.
Organising and developing the risk function’s governance through the leadership of the dedicated Risk Committee.
Development and monitoring of the Investment Risk controls to ensure and promote the independence of the second level controls of the risk function for the activities delegated from RIF to the affiliates in the UK.
Maintaining RIF’s incidents database and supporting RIF’s associates in the event of incidents and their remediation.
The successful candidate will have extensive demonstrable skills and experiences including the following:
RCCI’s professional license awarded by the AMF in previous employment is desirable.
Excellent experience of working with regulations/guidance issued by the AMF but also other EU authorities (i.e. ESMA) is needed.
Knowledge of AIFMD / MiFID II is required.
Demonstrating a consistent and uncompromising adherence to strong moral and ethical principles and values is required.
Ability to work collegiately within a small team structure in a very "hands on" role.
Good communication, listening, speaking, and writing skills at all levels of seniority and including English as a language.
Particularly strong report writing and policy/ procedure writing skills.
Essential to be approachable with an ability to act with diplomacy and summarise regulatory/legal information in a manner that associates can understand.
Experience of communicating with the AMF with its Supervision team
Experience of working at a senior level in institutional asset management compliance and familiar with regulatory matters connected to wholesale distribution of products to professional retail intermediaries.
A broad technical knowledge of financial products and services offered by RIF but also the wider group including, who offers them and how different functional teams interact.
Ability to assist the growth of RIF whilst being conscious of current and emerging regulations and regulatory strategies.
Experience of working in a multi-location global business is an advantage.
Self-motivated, strength to work under pressure, make difficult decisions and standby them, have good teamwork skills and an ability to organise and prioritise work.
Ability to determine what a new regulation means and what impact it will have on RIF and business activities.
A willingness to review new regulations, pick them apart, and to work with others to implement rules.