Chief Compliance Officer (CCO)
SCOPE OF JOB: The CCO is responsible for establishing and monitoring the enterprise-wide compliance program. This includes overseeing and managing the Banks Compliance Program which encompasses providing oversight and management of the AML/CFT Program (including the client acceptance process on a day-to-day basis), compliance with laws and regulations governing the banking activities both locally and internationally and ensuring conformance with the company's policies and procedures. The CCO is also the designated Nominated Officer based on the Proceeds of Crime Act and is the primary contact for regulatory and supervisor bodies on matters in relation to money laundering and the proceeds of crime and terrorist financing. The CCO reports directly to the Group Compliance Manager with a dotted line to the CEO of JMMB MB but works with all heads of department to optimize the compliance objectives. The CCO also reports to the Board of Directors and the Audit Committee at least on a monthly basis. Core Functions : Ensure the implementation and management of the compliance framework for the Bank Act as liaison between the Bank and the Bank of Jamaica, JDIC and law enforcement agencies (DPP, FID) with respect to compliance matters, investigations and examinations Provide guidance to team leaders to ensure compliance with applicable laws and regulations and guidelines issued by regulators Review design of policies, procedures and processes in order to minimize operational risk for the bank and ensure the update of policies is conducted. Evaluate new products and services to determine the level of risks as it relates to compliance with applicable laws, guidelines, policies and procedures Coordinate with the Bank's audit, legal and security departments on AML/CFT matters and investigations. Research proposed legislation and regulatory issues in order to identify processes that needs to be revamped or additional reporting that will be required Develop and coordinate training programmes that seek to ensure that all appropriate team members are knowledgeable of, and comply with, l regulations Manage Fraud matters for the Bank with the support of Internal Audit , liaising with authorities as necessary. Works closely with the senior managers of client departments to identify compliance issues arising out their operations and provide advice which will result in swift resolution of those issues. Guides the development of the Bank's documented policies and procedures for each functional area and participates in the review process as needed. Prepares, monitors and executes corporate actions and procedures in compliance with the Acts and Regulations which govern the conduct and affairs of the Bank Provide guidance & direction to team members within the Compliance Unit which includes Compliance Issues and Operational Risk matters. Perform in accordance with the roles and responsibilities of Chief Compliance Officer with respect based on the BOJ Guidance, Training of all team members of the bank in provisions of all the Acts, and all related laws, regulations and guidelines. Prepare monthly reports to the Board of Directors and provide the Board with updates to laws and Guidelines affecting the Bank Oversee and / or prepare the STR, TTR, listed entity reports and other reports required by FID Oversee and/ or prepare FATCA and other reports required by the TAJ Oversee and/ or prepare reports and due diligence queries from the JDIC Attend to court orders as required Act as department representative on assigned company and group projects Oversee administrative matters related to Code of conduct and compliance with AML/CFT Provides direction, fosters teamwork, leads and manages the Compliance Department to excite its Team Members to excellence and to facilitate its efficient, effective, caring operations. Promotes the JMMB's philosophy of the Vision of Love and its unique culture. Sound knowledge of business principles and practices; Bankers Association Representative MAIN DUTIES AND RESPONSIBILITIES : EDUCATION, TRAINING & WORK EXPERIENCE REQUIRED : Experience in the areas of compliance, legal or Audit Sound knowledge of banking regulations and procedures gained through the banking sector. REQUIRED SKILLS & SPECIALIZED TRAINING : In-depth knowledge and expert interpretation of FATCA and its supporting regulations , Proceeds of Crime Act and its supporting regulations, The Terrorism Preventing Act and its supporting regulations , The Banking Services Act and its supporting regulations, Companies Act, Financial Institutions Act, Securities Act and all other Acts and Regulations governing banking operations and the wider the Financial Services Sector. Sound knowledge of general banking principles and procedures. Excellent interpersonal skills Effective communication skills - both orally and in writing. Ability to work on own initiative and evaluate situations in order to make or recommend the most beneficial decisions in a timely manner. Sound working knowledge of computer operating systems. Ability and expertise to influence and implement “best practice” within the company and interface with the Executive, Management, team members , external Stakeholders and professionals in protecting and promoting the rights and interests of all elements of the companies' operations. RESPONSIBILITIES AND DUTIES : Being fully acquainted with the provisions of the Banking Services Act, Proceeds of Crime Act, the Terrorism Prevention Act and their amendments from time to time and their supporting regulations in addition to all other laws and guidelines affecting the entity. He/She must, in particular, be cognizant of the confidentiality requirements with regard to reporting transactions. Remaining informed of the local and international developments on money laundering and terrorist financing and industry best practices. The training of all team members of JMMB Bank with respect to the AML & CFT program and the applicable regulatory and legal requirements. Ensuring that all team members and Directors are kept up to date on current legislative requirements, both international and local. Establishing a compliance plan which will include on-going and independent review and on-going testing of staff compliance in order to achieve the Know Your Employee (KYE) Requirements. Implementing programmes, policies, procedures and controls to detect money laundering and terrorist financing activities. Establishing a reporting system whereby team members can report activities which are not in compliance with Bank's policies without fear of retribution. Submitting monthly and annual reports on the compliance programme to the Board of Directors and Executive Management. Have regular consultation with the Designated Authority, Competent Authority and the JDIC to ensure that the Bank is carrying out its obligations under the laws. Ensuring that reports for Threshold, Suspicious Transactions and Listed Entities are submitted to the Financial Investigations Division (FID) in a timely manner. Ensure that the applicable reporting under FATCA are submitted in a timely manner Ensure that all submissions due to the JDIC are submitted within the requisite time and that the entity is in compliance with the JDIC record keeping guidelines and other requirements of the JDIC; Ensure that all regulatory reports due from the Bank are completed in a timely manner Ensure that Ratios, limits and other restrictions noted in legislation affecting the Bank are adhered to and are reflected in the Policies, Procedures and processes of the Bank Evaluating reports of Suspicious or Unusual Transactions and verifying whether they are subject to reporting. Providing on-going training to the Compliance Officers and Bank team members Acting as liaison between the Bank and regulatory and law enforcement agencies with respect to all compliance matters and investigations. Ensuring that all exceptions are addressed and follow-up to ensure that corrective action is immediately instituted. Ensuring that adequate resources are in place to effectively monitor compliance. Evaluating new products and services to determine the level of risk and making appropriate recommendations. Liaising with the Bank's legal and audit departments on AML/CFT matters and investigations. Identify training programmes for Compliance Officers and Bank team members which will mitigate the risk of non compliance or breaches of the various regulationsProvides advice to the Executive and Senior management on a broad range of issues relating to products and services, policies & procedures and other general and/or complex matters pertaining to specialized areas of law relating to the Bank's operations Keeps current regarding developments in legislation and legal/business trends, and informs management of pending changes and how they will influence the business. Be involved in Project Teams to identify early legal problems and give guidance with a view to early resolution, reduction of expenses, and minimizing business risk. Assist in the maintenance of the correspondent banking and broker relationships by conducting the annual updates as requested and addressing concerns relating to AML/CFT and source of funds. Be a member of the Bankers Association Compliance Committee and such other Committee of the JBA as may be designated. To be actively involved at those meetings and meetings held with regulators and international bodies. Review new and amendments to existing legislation, guidelines on banking operations (including AML/CFT), discussions papers, issued to the JBA by Regulators and provide feedback in the allotted timelines.