About the Role

This role works closely with the Director of Regulatory Compliance and DPO, who leads the firm’s wider SRA regulatory compliance, data protection, complaints, supervision, audit, risk reporting framework. The Head of the NBI and MLRO is responsible for ensuring compliance with AML and CDD procedures.

Responsibilities

• Drafting and maintaining the firm’s conflict checking, case opening, anti-money laundering (AML) and related due diligence in relation to customer/client, funder, fee sharing or referral arrangement due diligence (CDD) procedures, and other anti-financial crime policies, controls and procedures and workflows, in compliance with regulatory requirements.
• Managing and supervising the NBI in client and matter onboarding and ongoing Conflicts AML and anti-financial crime monitoring.
• Ensuring that additional screening searches and enhanced due diligence are undertaken and analysed in relation to new and existing high-risk clients or matters, including potential politically exposed persons (PEPs), clients or matters that are located or operating in a high-risk jurisdiction, may infringe international sanctions, generate adverse media or potential reputational risks for the firm and any other issues which might be identified as high risk.
• Advising the RFC in respect of client conflicts of interest, confidentiality vs disclosure obligations in relation to new matter intake, commercial conflicts and matters under applicable RFC policies, in consideration of regulatory requirements and internal policies, including commercial conflict policies and the firm’s responsible business intake policy.
• Periodic reporting to the Managing Partner and Executive Committee of onboarding metrics and any key developments or issues relating to client onboarding, conflicts, AML and anti-financial crime compliance.
• Maintaining central register of high-risk clients and ensuring appropriate enhanced ongoing monitoring is applied for clients on the register.
• Maintaining appropriate records and reporting on New Business Intake and updating related policies, controls and procedures considering business intake decisions.
• Dealing with issues escalated by NBI, liaising with partners, fee earners and RFC to resolve conflicts, money laundering and other anti-financial crime risks and compliance issues that arise.
• Advising partners and fee earners on AML/CDD and anti-financial crime-related risks and requirements, including undertaking enhanced (or simplified) due diligence where appropriate under applicable firm procedures.
• Maintaining firm-wide risk assessments, policies, controls and procedures for New Business Intake and conflict checking, AML, sanctions, and related anti-financial crime controls.
• Monitoring new and amended legislation and regulatory changes and sectoral guidance, disseminating information to colleagues, developing and implementing new and amended policies, controls and procedures as necessary.
• Responsible as MLRO for receiving internal money laundering and terrorist financing reports, analysis of such reports and submission of suspicious activity reports (SARs) where appropriate. Maintaining MLRO Register to record decision making.
• Working closely with MLCO in relation to internal and external money laundering reporting, and all AML and anti-financial crime related policies, controls and procedures.
• Ensuring that information barriers are established with effective and proportionate controls and enforced as appropriate to conflict or confidential information risks identified for new and existing clients/matters. Ensuring firm’s Intapp Walls information barrier systems are maintained, updated and audited.
• Assisting and collaborating with other stakeholders across the firm with other regulatory, professional conduct and ethics-related enquiries, tasks and projects.
• Coordinating external, independent audit of firm’s AML controls, policies and procedures, liaising with auditors and implementing recommendations where required.
• To work alongside the Regulatory Compliance Director & DPO and Compliance department to ensure a seamless multi-faceted service to the firm.
• Liaising and collaborating with other areas of the business and key stakeholders, including fee earners and members of HR, IT, Projects, Accounts and Marketing, on regular processes (including input in relation to annual practising certificate and PII renewals where NBI, conflicts, AML, sanctions or anti-financial crime issues arise) and firm-wide projects.
• Preparing and delivering firm-wide and department specific training in relation to new case/client and conflict checking procedures and post-matter inception requirements information barriers, AML, anti-facilitation of tax evasion, anti-bribery and corruption, anti-fraud and other anti-financial crime related risks, coordinating with Regulatory Compliance Team where wider compliance or data protection content is involved.
• Providing ad hoc risk assessment, due diligence and ongoing monitoring support and advice in relation to client service providers and other third parties as required.
• Negotiating and maintaining firm’s relationships and contracts with risk screening, due diligence and other software providers relating to AML and anti-financial crime functions. Identifying requirements for new or updated services and systems when necessary and leading on related internal projects when required.