Head of Risk and Compliance (‘HRC’)/ Money Laundering Reporting Officer (‘MLRO’) / Data Protection Officer (‘DPO’)

Location: Isle of Man
Term: Full-time

The HRC is responsible for the monitoring, management, training, and compliance with the relevant legislation and regulation (and where appropriate best practice) relating to compliance and risk matters of Cayman National’s Isle of Man regulated entities – Cayman National Bank (IOM) Limited and Cayman National Trust Company (Isle of Man) Limited – collectively ‘CNIOM’.

The HRC has direct access to the Boards and holds a senior role within the local management team and has the authority, independence, and status to access information, systems, and decision-makers to carry out his/her duties effectively.

The HRC role is approved by the Financial Services Authority (‘FSA’) and charged with responsibility for overseeing compliance of CNIOM’s operations with all regulatory requirements, including those relating to preventing money laundering and combating the financing of terrorism. They are also responsible for overseeing the management and reporting of business risks, including the monitoring of risk reduction and mitigation measures.

The MLRO is an FSA approved role appointed to ensure compliance with the reporting and management of suspicious transaction reports as documented in the regulations.

Role Responsibilities

• The management and oversight of the CNIOM Compliance Monitoring Program
• To ensure appropriate reporting is made as appropriate to the Committees and Boards and to act as Deputy Chair of the Isle of Man Audit, Risk, and Compliance Committee
• To collate and manage the recording of risks under the Risk Management process, reporting to Group as required within specified timeframes
• To ensure all relevant registers are maintained in line with the regulatory requirements
• As MLRO the review of internal Suspicious Transaction Reports in the light of all available relevant information and determining whether such internal reports have substance and require disclosure to the Financial Intelligence Unit
• Maintaining related records particularly documentation relating to the evaluation process regarding suspicious transactions and the rationale for decisions taken
• Providing support and guidance to the Boards and staff to ensure that money laundering and terrorist financing risks are adequately managed
• Managing the training regime to ensure that all staff are appropriately trained in AML matters, including induction training, and annual refresher training programs
• As DPO, to ensure Privacy Impact Assessments are carried out prior to a change in processing to ensure the rights of the Data Subject are being protected
• To notify the Supervisory body within the specified timeframes upon the identification of a data breach
• To record and respond to subject access requests within the prescribed timeframes and in accordance with the requirements of the relevant legislation
• To ensure all staff properly implement Board approved policies, comply with the record retention timeframes, and complete the prescribed training as and when required

Requirements

• Relevant professional qualifications related to the role
• Thorough knowledge of the business areas of CNIOM – Banking and Fiduciary Services
• Analytical, ability to work to deadlines, decision maker, self-confidence, and maturity to know when to overrule management or escalate matters. Excellent influencing and communication skills
• 5 years’ experience in a similar role