Head of Compliance, Governance, Regulatory and Secretariat

Location: Jersey

Closing date: 02/12/21

Role purpose:

We are looking for a Head of Compliance, Governance, Regulatory and Secretariat to join our Senior Management Team, reporting directly to the Chief Risk Officer (CRO). They will oversee the development and deployment of the Compliance, Governance, Regulatory and Secretariat framework and strategy for all relevant segments and functions within the bank. In addition, this role will also undertake the responsibilities of Data Protection and Information Security Officer. We are looking for someone who has extensive experience and knowledge of the UK, Jersey and Isle of Man banking markets, law and regulation compliance strategies, who holds a Diploma in Money Laundering (or similar) with 5 years + post qualifying experience.

Key accountabilities:

Scope of role:

  • A member of the Senior Management Team managing a team responsible for the design, implementation, monitoring and development of compliance, governance and regulatory policies and procedures within Santander International covering the UK regulators and Jersey and Isle of Man branch regulators to ensure cost-effective operation of the business and full compliance with all jurisdictionally relevant legal and regulatory requirements, Santander Group requirements and market best practices
  • To head the internal secretariat function liaising closely with the Santander UK Holding Company (“HoldCo”) Secretariat with responsibilities and accountabilities as described in the relevant jurisdictional Company Law
  • To maintain effective oversight over all business lines operated within Santander international
  • Responsible for the execution of strategy and the development, management and delivery of Data Protection and Privacy arrangements that facilitate the company’s compliance with regulations
  • Take responsibility for overseeing data privacy compliance programmes.
  • To be responsible for running all regulatory liaison and the point person for ensuring UK regulatory interaction is managed effectively in accordance with the service level agreements place with the HoldCo
  • To support the CRO in any other Second Line of Defence (2LoD) matter they deem suitable from a regulatory, compliance and secretariat perspective
  • Chair of all Compliance (CDCC), Onboarding & Exiting (OBE), and Regulatory forums
  • Regular contributor and participant to all Committees including ExCo, Board, Board Risk Committee and Board Audit Committee
  • Initially undertake the “Compliance Officer” designation for Jersey Branch with the JFSC
  • Mitigating operational losses through efficient governance processes
  • Mitigation of regulatory breaches and accompanying financial fines
  • Mitigation of client complaints in respect of data protection issues to support service enhancements and complaint related costs
  • Incumbent team of 4 with plans to expand in line with our future growth aspirations
  • This is a line 2 role as defined by the Santander Risk Framework

Managing Risk

  • Works to ensure that all legal and regulatory risks are minimised, and appropriate compliance, systems and controls in place to manage risk
  • To ensure compliance with legal, regulatory and constitutional obligations for each jurisdiction. This will typically include Companies Act, Stock Exchange, Banking, Trademark and other legislation, regulations and codes of practice for each jurisdiction
  • To analyse and provide specialist advice on new business and company law developments in order to clearly identify any statutory, compliance, corporate and prudential control risk implications and influence projects to ensure that best practice standards are met and compliance with the relevant legislation for each jurisdiction
  • Ensure the business is compliant with industry changes and Government legislation particularly in regard to Tax requirements and is aligned to Santander requirements
  • Ensure Regulators and other external bodies are provided with requisite information and that recommendations are implemented
  • Ownership for all Regulatory submissions and correspondence ensuring that stakeholders from the Santander Group are fully engaged and expertise leveraged wherever possible
  • Liaise closely with HoldCo and Group legal and be the person responsible for ensuring Santander International discharges all current and upcoming regulatory responsibilities in the UK, Spain, Jersey and Isle of Man and any other future jurisdictions we operate in
  • Assume ownership for full compliance with all statutory and regulatory requirements with timely and accurate reporting to the CRO for onward reporting or direct reporting where appropriate to the Santander Group, and its Boards and the regulators within each justification where Santander International operates
  • To provide professional company secretary services, ensuring statutory compliance and effective controls for all governance forums, excluding Board level meetings
  • To work with HoldCo to ensure effective Board oversight and secretariat is provided, subject to the Service Level Agreements in place
  • Oversee the embedding of policies into business functions and ensure that policies are consistent with overall data protection and privacy rules
  • Maintain data protection policies and procedures - monitor compliance with data protection laws and Group policies
  • Oversee the maintenance of records required to demonstrate data protection compliance
  • Supervise and advise on Data Protection Impact Assessments (‘DPIAs’)
  • Manage the GDPR assurance program and related audits
  • Maintain the data protection breach register
  • Be the point of contact for, and co-operate and consult with the Information Commissioners in Jersey and the Isle of Man
  • Operate and embed an effective Compliance monitoring program into the business
  • Be the sole point of contact for customers and other data subjects, i.e. employees, former employees, contractors or suppliers when exercising their rights in respect of their personal data

Customer

  • Develops and maintains excellent relationships with senior management across Santander International and the wider Santander Group
  • Demonstrate effective understanding of internal and competitor/industry trends
  • Subject Access Requests (‘SARs’) managed within Service Level Agreements (‘SLAs’) in 100% of cases, and actions implemented to rectify root cause issues identified/trend analysis
  • Data Protection oversight support of implementation of new business and process changes within the wider business to improve business performance and establish best practice

Legal and Regulatory

  • Ensuring that Santander International have robust arrangements for compliance with the Banking Law, related Orders and Codes of Practice
  • Ensuring appropriate monitoring of operational performance and promptly instigating action to remedy any deficiencies in such arrangements
  • Prove the principal point of contact with the Regulators on all regulatory matters and the Santander UK regulatory liaison team for all UK regulatory matters
  • Ensures that appropriate systems and controls are in place so that Santander International operates effectively
  • Does not enter into business relationships with prohibited clients as defined by UK and Group standards
  • Collects and maintain sufficient Know Your Customer (KYC) and Know Your Business (KYB) information to satisfy the minimum Customer Due Diligence (CDD) requirements for all clients
  • Collects and maintain enhanced KYC and KYB information for clients using a risk based approach
  • Collects and maintain information to satisfy the minimum tax requirements for all clients
  • Complies with FATCA, CRS and UK IGA and other international regulations that apply

Policies & Procedures

  • Ensure that the businesses have all relevant and required Compliance and policies documented and approved by the Board, adopting Santander UK or Group policies where possible and appropriate
  • Reviews and amends existing Compliance policies to ensure that the controls and limits are appropriate and are approved by the Santander International Risk, Compliance, Financial Crime and Governance Forum (SIRCFCGF) and the Boards of each respective business operating within the Crown Dependencies.
  • Ensures all Compliance policies are compliant with Santander Group best practice Standards, and guidelines from local regulators and that the rationale for any deviations are documented
  • Continually assesses the Compliance framework and the requirement for new policies
  • Ensures legal requirements and Compliance emerging events are considered by the respective Boards and that proposals approved by the Boards to mitigate risks are communicated effectively to the business and are implemented within agreed timescales

Evaluation and Reporting

  • Designs, develops and produces accurate and timely reports to facilitate effective monitoring of Compliance issues by the respective Boards, the SIRCFCGF, SMT and relevant divisions within Santander UK and the Group
  • Manages relationships with Regulated Financial Intermediaries (working closely with the relevant Segment Head), including maintaining suitable registers, initial and ongoing visits and reporting thereon internally to the relevant forum/committee

Continuous Improvement

  • Ensures ongoing compliance with new and existing legislation, regulation and industry guidance, ensuring that Santander International keeps fully abreast of the changing Compliance environment
  • Responsible for the design and delivery of the annual Compliance Monitoring Plan
  • Approves the implementation and monitoring of new standards and risk strategies in order to mitigate regulatory and reputational risk
  • Makes a significant contribution to the leadership of required change within Change Management framework and governance structure.

Project and Change Management

  • Provides a responsive, quality and timely advisory service on all compliance, regulatory, legal and governance related matters to project managers and managers based on:clearly articulated business strategies, product terms and conditions and project terms of reference
  • Manages and/or influences projects, new product development, advertising plans to ensure that compliance requirements/standards are met in a cost effective and timely manner
  • Provides a responsive and timely advisory service on all day-to-day Compliance matters e.g. sign off of all customer communications
  • Effective management of business demand and the prioritisation process for projects
  • Strict adherence to Group expenditure control processes and strong financial evaluation of projects
  • Effective implementation of change management standards and policies within the Santander Group as required
  • Effective delivery of change management programs to meet agreed strategy

Competencies:

Behavioural:

  • Working as a Team and Team Management
  • Client and Customer Orientation
  • Results Orientation
  • Innovation and Managing Change
  • Communicating and Influencing

Technical:

  • Compliance awareness
  • Regulatory expertise
  • Risk Management and Control
  • Information and Data Management
  • Service/Solutions Delivery
  • Business and Product Knowledge

Skills / Qualification:

Technical Knowledge

  • Extensive experience and knowledge of the UK, Jersey and Isle of Man banking markets, law and regulation compliance strategies. Fully aware of both their own, and the business’ obligations under all relevant local legislation
  • Experience with delivery of best practice compliance monitoring programmes and controls and quality assurance checks to ensure business meets the required compliance standards
  • Excellent analytical, interpretation, influencing and communication skills; ability to communicate and network effectively and influence top management and external parties
  • Ability to analyse and evaluate complex issues, and sound judgement in determining appropriate actions/solutions

Qualifications & Experience

  • Extensive experience and knowledge of appropriate law and regulation developed over at least seven years in appropriate legal / regulatory / financial services roles that included reporting to internal (risk and compliance governance committees) and external authorities. Is fully aware of both his/her and the business’ obligations under the Proceeds of Crime Law, Drug Trafficking Offences Law, Terrorism Law, United Nations Measures and the Money Laundering Order (and by extension, also the Handbook)
  • Experience with the delivery of best practice Compliance monitoring programmes, including systems and controls and quality assurance checks to ensure business meets the required standards.
  • Experience with maintaining appropriate policies and to apply procedures, and to monitor the business’ compliance with those policies and procedures to satisfy all legislation within the UK, Jersey and Isle of Man relating to Compliance issues
  • Experience with working with functional reporting lines to Group Compliance functions and in so doing leveraging Group resources successfully to maintain compliance
  • Must be able to act independently in the execution of duties and directly influence the business so ensuring appropriate action is taken where necessary. Proven track record in providing advice and developing and owning solutions to Compliance issues
  • Proven experience at a sufficient level of seniority and authority within a regulated business so that the respective Boards reacts to and acts upon any recommendations made. Is fully competent to have regular contact with the Board so that the Board is able to satisfy itself that statutory obligations are being met and that the business is taking sufficiently robust measures to protect itself against the risk of money laundering and financing of terrorism
  • A minimum of five years proven people management experience in a regulated environment with a track record of delivering to meet agreed objectives in a financial services organisation environment
  • Demonstrated experience in developing good relationships with senior management and supporting departments with the information necessary to appropriately perform the function of Compliance Officer
  • Excellent analytical, interpretation, influencing and communication skills; ability to communicate and network effectively and influence top management and external parties
  • Ability to analyse and evaluate complex issues, and sound judgement in determining appropriate actions/solutions
  • Experience and successful proven track records of owning and driving change in a regulatory environment to maintain full compliance with all legal and regulatory requirements.
  • Able to demonstrate a strong focus on personal development
  • Membership of a relevant Compliance qualification
  • Approved Person by a regulatory body
  • Educated to Degree level is likely, preferably in a relevant subject (Banking, Financial Marketing, Business Management) or other professional qualification such as International Diploma in Money Laundering with 5 years + PQE

There has never been a better time to join Santander International, so if you feel that you are looking for a career that will challenge, excite and motivate you, then you are looking in the right place.

This is a permanent role working 35 hours per week and attracts a competitive salary and benefits package, including private medical insurance, contributory pension scheme (post probation).

Santander International has a fantastic culture, is committed to, and has a strong presence in our local community and creates a sense of belonging through great social events. 

If you are interested in becoming part of our team or wish to know further information regarding this role please email Annette Cullen (Director, Human Resources) or Ryan Williams (HR Manager)  or telephone +44 1534 828 166 or +44 1534 885 122. To apply for the role, please click on the apply button so you can submit your details and your CV and covering letter.