Compliance Officer & MLRO - Chile

Compliance Officer & MLRO – Chile

Ebury Santiago - Hybrid: 4 days a week office based working, 1 day working from home

The Chilean Compliance Officer & MLRO, reports directly to the Chief Compliance Officer & GMLRO. The main purpose of the role is to maintain the integrity of the Chilean branch, ensuring adherence to legislative requirements and providing support to the wider group. In addition this role requires oversight of regulatory obligations, requirements and implementing findings into policies and procedures. In their role, the Compliance Officer & MLRO is trusted with responsibilities which include:

• Review of SAR escalations from the Financial Crime Compliance Investigation Team and where appropriate file them with the FIU;
• Review and approve escalations from the front office/first line of defence in regards to:
• Waivers;
• PEP Role Discounting;
• PEP Declassications;
• Exceptions from policy;
• Major negative media;
• EDD Approvals;
• Blacklist hits;
• Military/Dual Use Goods queries;
• Proliferation financing queries;
• Sanctions/Civil Penalty hit (in consultation with FCC Sanctions);
• Sanctioned Country Connection (in consultation with FCC Sanctions);
• Sanctioned Risk Assessments (in consultation with FCC Sanctions and subject to final approval from the Group MLRO);
• Financial Crime Investigations (in consultation with FCC Investigations and subject to final approval from the GMLRO);
• Sanctions Investigations (in consultation with FCC Sanctions and subject to final approval from the GMLRO);
• Dispensations (in consultation with FCC Advisory and subject to final approval from the GMLRO);
• Risk downgrades (in consultation with FCC Advisory and subject to final approval from the GMLRO);
• Liaise with the front office with any questions about policies and procedures; 
• Assist to relevant Forums, Working Groups and Committees where Compliance/MLRO advice is needed;
• Keep up to date with relevant AML and Financial Crime regulations and changes; 
• Policy drafting and reviewing, ensuring that the local policies and procedures are consistent with the group, but also ensuring that they are compliant with the applicable local regulations and laws;
• Conducting research for ad hoc regulatory queries from other departments or Senior Management; 
• Be the direct contact person with the Regulator (CMF & UAF) and assure a good relationship and cooperation;
• Drafting and preparing the regulatory periodic deliverables and drafting regulatory communications; 
• Coordinate as key point of contact for AML Audits (internal & external) and ensure that the information provided is accurate and up-to-date;
• Perform remediation works of findings by both internal and external audit, as well as recommendations set by the Regulator;
• Provide inputs to periodic financial crime management information;
• Identify local financial crime/regulatory training needs and provide training about products, financial crime, regulatory obligations etc. to the front office and sales teams;
• Ensure monitoring of the first line of defence from a second line of defence perspective to identify any issues and concerns;
• Assist the Regulatory Operations team in the implementation of AML Reporting by translating local legal requirements into operational guidelines. Liaise with regulators and other regulatory bodies to this end as appropriate; 
• Identification and completion of local regulatory reporting requirements;
• Assist the business units and Senior Management with ad-hoc queries where appropriate (i.e. in scope and not already covered by a dedicated team e.g. KYC Advisory);
• Responsible for the complaints handling for the branch with the responsibility to communicate with the client, investigate the complaint and take decisions on the redress of the complaint (up to and including whether the complaint will be upheld or not);
• Manage relationships which are considered as having conflicts of interest and ensuring that the management rules set in place are followed by all parties. Conflicts of interest are dealt with at a group level, however, the Compliance Officer & MLRO is required to be aware and ensure that it takes actions agreed during the all stages;
• Assist in the investigations on breaches that involve the branch and assist in the investigation process with the group level compliance. 
• Coordinate with the wider regulatory compliance team regarding applicable changes and implementation of new procedures and controls.

As the position of Compliance Officer & MLRO is described as “independent” the responsible person in the role is expected to take decisions which may directly affect the branch and the overall business. The role of a Compliance Officer & MLRO is required to be senior enough to have the ability to take decisions on the ground to protect Ebury, its clients and its various counterparties. In their role, the Compliance Officer & MLRO participates in various working groups, committees and other important functions including: 

• The Financial Crime Working Group (monthly); 
• Integral member of the local Client Risk Acceptance Forum (weekly); and
• Compliance Management Committee (weekly)
• Chilean Client Review and Acceptance Forum (ad hoc)

Finally, the Compliance Officer & MLRO of the branch should maintain a good working relationship with the Country Manager, and would possess the right and ability to oppose decisions that are deemed to be non-compliant with our regulatory obligations, group policies and anything relating to financial crime. The person holding this position, by definition of the responsibilities assigned, will be deemed to be the most senior member of compliance in Chile with authority to take actions necessary to protect the integrity of Ebury and protect its licence and overall reputation. 

Proficiency in English and local language is required while any professional certifications or a law/economics degree will be considered a plus.

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