Alexander Charles
Deputy Money Laundering Reporting Officer (DMLRO) / AML & Financial Crime Officer London £70,000 plus 20% bonus
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Deputy Money Laundering Reporting Officer (DMLRO) / AML & Financial Crime Officer
The Deputy Money Laundering Reporting Officer (DMLRO) / AML & Financial Crime Officer is responsible for supporting the MLRO in the effective management of the firm’s anti-money laundering (AML), counter-terrorist financing (CTF), sanctions and wider financial crime framework.
The role acts as a key point of contact for the business, providing practical, risk-based advice and guidance on AML, KYC, CDD, EDD, sanctions, PEPs, Source of Funds (SOF), Source of Wealth (SOW) and wider financial crime matters. The role will work closely with front-line business teams to ensure financial crime risks are appropriately identified, assessed, mitigated and escalated.
The role will also undertake risk-based monitoring reviews of customer and mortgage/secured loan files to assess the effectiveness of first-line controls, the quality and consistency of AML decision-making, and compliance with the Money Laundering Regulations 2017, JMLSG Guidance, Group policies and procedures.
As Deputy MLRO, the role will support and deputise for the MLRO as required, including providing appropriate escalation, challenge and support in relation to financial crime risks and concerns.
The role will work closely with the MLRO, Second Line Compliance, Risk and business stakeholders to promote a strong culture of financial crime risk ownership and to identify and address control weaknesses and emerging risks.
Key Accountabilities:
Deputy MLRO Responsibilities
- Support the MLRO in the effective discharge of their AML and financial crime responsibilities.
- Deputise for the MLRO when required and act as an escalation point for significant or complex AML and financial crime matters.
- Provide appropriate advice and challenge to the business on customer and transaction-related financial crime risks.
- Support the assessment and escalation of unusual, complex or potentially suspicious activity in accordance with internal procedures.
- Support the MLRO in identifying emerging financial crime risks, recurring issues and weaknesses in the firm’s AML control environment.
- Maintain effective communication with the MLRO and Second Line Compliance regarding material AML risks, monitoring findings and areas requiring further action.
- Support the implementation of changes arising from regulatory developments, internal reviews, monitoring activity and changes to the Group financial crime framework.
Business Advice and Guidance
- Act as a key source of AML and financial crime advice for front-line business teams.
- Provide timely, practical and risk-based advice on AML, KYC, CDD, EDD, sanctions, PEPs, SOF, SOW and adverse media matters.
- Assist business teams in assessing and resolving complex or unusual customer and transaction scenarios.
- Provide challenge where proposed decisions or risk assessments do not adequately reflect the available information or applicable requirements.
- Support the business in reaching consistent and appropriately documented risk-based decisions.
- Provide ad hoc training, coaching and guidance to supplement Group-wide AML and financial crime training.
- Promote a strong culture of compliance and ownership of financial crime risk across the business.
Customer and File Reviews
- For new customers, assess AML and financial crime risk in line with the Group financial crime framework and regulatory requirements.
- Conduct and/or support CDD, EDD and KYC reviews and ensure appropriate records of decisions and customer risk assessments are maintained.
- Review mortgage and secured loan files prior to completion to ensure that applicable AML, financial crime and regulatory requirements have been satisfactorily completed and evidenced.
- Review customer identification and verification requirements in accordance with the Money Laundering Regulations 2017, JMLSG Guidance and Group policy.
- Review and assess Source of Funds and, where required, Source of Wealth documentation to ensure there is a clear and auditable rationale supporting the customer’s contribution to the transaction.
- Review sanctions, PEP and adverse media screening results and ensure alerts or potential matches have been appropriately investigated, documented and approved.
- Verify that customer risk assessments accurately reflect the customer’s risk profile and that EDD requirements have been applied where appropriate.
- Identify inconsistencies, unusual activity, complex arrangements or other indicators of potential financial crime and escalate concerns in accordance with internal procedures.
- Ensure relevant AML, KYC, fraud prevention and financial crime conditions have been satisfied before completion and fund release.
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AML & Financial Crime Monitoring
- Undertake risk-based monitoring reviews of completed and/or in-progress mortgage and secured loan files to assess adherence to AML and financial crime requirements and internal procedures.
- Develop and maintain an appropriate programme of file-based monitoring reviews, informed by customer risk, business activity, emerging risks, previous findings and areas of known control weakness.
- Assess the quality and effectiveness of AML/KYC controls, including CDD, EDD, customer risk assessments, sanctions and PEP screening, SOF/SOW and the rationale supporting decisions.
- Identify control failures, inconsistencies, recurring issues and areas where additional guidance or remediation is required.
- Document monitoring findings clearly, including the underlying issue, risk, root cause where appropriate and recommended remedial action.
- Provide feedback and recommendations to relevant business teams and agree appropriate corrective actions where required.
- Monitor the completion of agreed actions arising from file reviews and escalate overdue or material issues appropriately.
- Identify trends and themes arising from monitoring activity and provide these to the MLRO and relevant stakeholders.
- Support the MLRO and Second Line Compliance in understanding the effectiveness of first-line AML controls.
- Ensure monitoring activity is appropriately evidenced and maintains a clear audit trail.
- Where monitoring identifies potentially material or systemic weaknesses, escalate these promptly to the MLRO and relevant senior stakeholders.
Monitoring undertaken as part of this role is intended to provide effective first-line control assurance and challenge. It does not replace or duplicate the independent second-line Compliance monitoring and oversight framework.
Governance, Risk and Regulatory Support
- Maintain complete and accurate audit trails and records demonstrating compliance with the Money Laundering Regulations 2017, JMLSG Guidance and internal policies.
- Identify control weaknesses and recommend improvements to AML and financial crime processes and procedures.
- Support the MLRO in preparing for and responding to regulatory, internal and external audits and reviews.
- Assist with requests from Compliance, Risk and other relevant governance functions.
- Support the implementation of new or updated AML policies, systems, procedures and regulatory requirements.
- Contribute to the review and enhancement of AML and financial crime controls based on monitoring findings, business changes and emerging risks.
- Promote a strong culture of compliance, effective challenge and ownership of financial crime risk across the business.
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Skills & Competencies
- Experience working within an AML, KYC, Financial Crime, MLRO/DMLRO or First Line of Defence environment.
- Good understanding of AML, CTF, sanctions and wider financial crime regulatory requirements.
- Experience providing AML and financial crime advice to business stakeholders.
- Experience undertaking risk-based file reviews, quality assurance or monitoring activity.
- Knowledge of CDD, EDD, PEPs, sanctions screening, adverse media screening and financial crime risk assessment.
- Strong analytical, investigative and monitoring skills with excellent attention to detail.
- Ability to identify control weaknesses, assess risk and provide appropriate challenge.
- Ability to make sound risk-based decisions while balancing customer experience and regulatory requirements.
- Ability to communicate complex AML and financial crime requirements clearly to non-specialist business colleagues.
- Ability to work collaboratively with Compliance, Risk, Operations and business stakeholders while maintaining appropriate independence and challenge.
- Experience reviewing mortgage, secured lending or property finance cases would be advantageous.
Knowledge & Qualifications
- Strong knowledge of the Money Laundering Regulations 2017, JMLSG Guidance, Proceeds of Crime Act 2002 and UK sanctions requirements.
- Strong understanding of Source of Funds and Source of Wealth assessment principles.
- Knowledge of the role and responsibilities of an MLRO and the expectations applicable to a Deputy MLRO.
- Ability to identify inconsistencies within customer information, documentation and transaction activity and make appropriate risk-based decisions.
- Relevant experience within a non-bank lender desirable.
- ICA Certificate or Diploma in Anti-Money Laundering or equivalent relevant qualification desirable.
Personal Attributes
- Strong attention to detail and problem-solving skills.
- High levels of integrity, independence and accountability.
- Confident in providing advice, challenge and escalation.
- Effective written and verbal communication skills.
- Ability to build trusted relationships with business stakeholders while maintaining appropriate professional challenge.
- Pragmatic and commercially aware, with the ability to apply a risk-based approach.
- Strong team collaboration and stakeholder management skills.
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