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Job Title: Compliance Officer
Location: London (office-based, five days per week)
Reporting Line: General Counsel & CCO
Regulatory Status: Conduct Rules staff under the FCA Code of Conduct (COCON)
Level for Referral Policy: Junior
Who We Are
Marble Bar Asset Management LLP ("Marble Bar") is a leading London-based alternative investment manager, established in 2002, with approximately US$3 billion of assets under management. The firm specialises in equity strategies, but operates across a number of different asset classes. In 2016 we launched The Partners Business and opened our integrated architecture to independent hedge fund managers, supporting them initially as they navigate the fragile early stages of building their businesses.
The firm is authorised and regulated by the Financial Conduct Authority as a full-scope UK Alternative Investment Fund Manager, and is registered with the U.S. Securities and Exchange Commission as an investment adviser.
What We Do
Marble Bar operates a form of multi-manager platform. Investment teams are established as partner firms using a combination of Appointed Representatives and Secondments into Marble Bar, which generally acts as AIFM and is responsible for all regulated activity, including portfolio management, financial promotions and regulatory reporting. The firm provides the institutional infrastructure around each strategy: legal and compliance, risk, operations, technology, treasury and investor relations. Strategies on the platform span equity long/short; market neutral; event driven, and credit, principally through Cayman master-feeder funds and managed accounts but with a growing number of onshore fund vehicles.
The consequence for the compliance function is a broader remit than firm size alone would suggest: multiple funds, multiple investment teams, two lead regulators and a continuous flow of new mandates and structures onto the platform.
Your Role
Compliance is presently a two-person function comprising the General Counsel & CCO, and an existing Compliance Officer who would be working alongside the successful candidate. The team supports every part of the firm and its investment teams, and reports to the Executive Committee and the Partnership Board.
The Compliance Officer will work with the team to help deliver the firm’s compliance programme, taking day-to-day ownership of elements of the monitoring, surveillance, registers, regulatory reporting and the review of investor-facing materials, as well as providing advisory support to investment teams and central functions. The role is deliberately broad and suits a candidate who wants direct responsibility across the full FCA and SEC perimeter rather than a single specialism.
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Your Key Areas of Impact
Monitoring and surveillance
- Own and operate elements of the annual compliance monitoring programme, including scoping reviews, performing testing, writing reports and tracking remediation to completion.
- Conduct market abuse surveillance, including deep-dive trade reviews, communications review and escalation of alerts, applying a working understanding of the strategies traded on the platform.
- Deal with the restricted list and sanctions screening programme on a day-to-day basis, including inside information handling and wall-crossing procedures.
- Maintenance of the firm’s compliance registers, including personal account dealing, gifts and entertainment, outside business interests, breaches, errors and incidents.
Regulatory reporting and governance
- Prepare and submit regulatory returns to the FCA and support SEC reporting obligations, including Form ADV and Form PF, working with the firm’s advisers where required.
- Prepare compliance reporting for the Executive Committee, the boards of the managed funds and, where required, investors and their consultants.
- Administer staff attestations, certification and fitness and propriety processes, and training records under SM&CR.
- Support responses to regulatory correspondence, examinations, due diligence questionnaires and investor operational due diligence.
Fund, investor and counterparty documentation
- Review legal documentation relating to the funds, managed accounts, partner firms and service providers, and maintain the firm’s documentation record.
- Maintain offering memoranda, prospectuses, side letters, non-disclosure agreements and service provider agreements, and track the obligations arising from them.
- Review and approve financial promotions and investor communications, including factsheets, presentations and investor letters, and advise on the marketing rules applicable in the relevant jurisdictions.
Advisory, policy and training
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- Advise investment teams and central functions on day-to-day regulatory questions, including trading rules, disclosure obligations, conflicts and inducements.
- Research developing law and regulation, assess the impact on the firm and its funds, and update policies and procedures proportionately.
- Design and deliver compliance training that reflects the firm’s actual risk profile and current regulatory expectations.
What We Are Looking For
Essential
- At least five years’ experience in a compliance or legal role in asset management, ideally within a hedge fund, alternative investment manager or comparable regulated firm.
- Working knowledge of the FCA Handbook as it applies to an AIFM and MiFID investment firm, and of the U.S. Investment Advisers Act framework applicable to an SEC-registered adviser.
- Familiarity with offshore and onshore fund structures, including Cayman master-feeder funds and managed accounts.
- Practical experience of compliance monitoring and market abuse surveillance, including forming and documenting a view on individual trades.
- The judgement to give a clear answer on an unfamiliar question, and the discipline to record the reasoning behind it.
- A self-starter comfortable resolving matters independently in a small team, and escalating appropriately when the position is not clear.
- Precise written English and the ability to communicate a regulatory position credibly to portfolio managers, senior management and fund directors.
Desirable
- Experience of algorithmic trading, including the FCA and SEC regulations and rule-sets that apply to its usage.
- Experience of a multi-manager, platform or seconded-personnel operating model.
- Experience of SEC examinations or FCA supervisory engagement.
- Exposure to surveillance, order management or compliance monitoring systems, and a willingness to improve how the function uses them.
- Capacity to assist the General Counsel & CCO on ad hoc legal and corporate matters.
The role is based in the firm’s London office, with an expectation of attendance five days per week. The appointment is subject to satisfactory regulatory references, fitness and propriety checks and the firm’s standard pre-employment screening. Remuneration will be commensurate with experience and is subject to Marble Bar's remuneration policy.
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