Job Title: Head of Financial Crime (MLRO/SMF17 for Beazley Furlonge Limited and BIdac UK)
General Management –Risk & Compliance
Reports To: Head of Operational Risk
Key Relationships
Head of Operational Risk, Group CRO, Head of ERM, Head of Insurance Risk, Entity CROs, Entity Heads of Compliance, Business Manager to the Group CRO, Controls & Compliance Assurance team, Head of Internal Audit, Chief People & Sustainability Officer, Group and Entity CUOs, other internal stakeholders as required including BFL Management Committee, BFL Board and Risk Committee members, BIdac UK branch Senior Managers, BISIL UK branch Senior Managers, European Branch Committee members, Group, UK, EU and US regulatory authorities, financial crime regulatory agencies, including OFAC, HMT, EU, external auditors and external counsel.
Job Summary
Responsible for oversight of the 2nd line financial crime team and maintaining an effective financial crime function and framework across the Group. As a leader within the 2nd Line, assist the Head of Operational Risk by delivering effective risk management strategies against financial crime risk that contribute to a robust control environment. PRA/FCA SMF17 MLRO for the following group entities: Beazley Furlonge Limited (BFL) and Beazley Insurance designated activity company (BIdac) UK branch and all associated companies.
Key Responsibilities
Management
- Line management of the financial crime team to include regular team meetings, 1:1s, action setting and tracking, performance assessment and associated responsibilities.
- Member of appropriate governance forums/committees as required.
- Management of any relevant external advisors as required.
Financial Crime
- Manage and maintain an effective Financial Crime function supporting and protecting the group against the six pillars of financial crime risk (Bribery & Corruption, Fraud, Market Abuse, Money Laundering, Sanctions Evasion and Tax Evasion) and related reputational risk ensuring that the needs of all stakeholders are met.
- Ensure the resourcing model, quantity and quality of resources enable the Financial Crime Function to meet the group’s needs. This includes establishing a cost-effective approach to achieving target compliance.
- Develop and maintain Beazley’s financial crime policy in line with legislative and regulatory obligations, ensuring the policy remains up to date.
- Produce regular financial crime reports and present to appropriate Boards and Committees when required.
- Act in an advisory capacity to support business heads and management focus on the financial crime risk in individual business areas.
- Assist senior management in development and maintaining an effective financial crime compliance culture.
- Ensure that the firm’s risk management policies, risk assessment profile and their application are adequately documented and approved by Beazley’s Executive Committee and Board of Directors.
- Create and maintain the financial crime risk-based approach and, where applicable, the risk assessment of Beazley’s customers, products and services, country and delivery channel risk.
- Document Beazley’s risk-based strategies in relation to financial crime compliance, as well as the basis for the risk-assessment.
- Monitor that all internal SARs received are investigated.
- Write external SARs and ensure that these are submitted to the relevant law enforcement agency in respect of all suspicions; ensure that these are meaningful and of good quality.
- Ensure that all staff are aware of their personal and regulatory obligations in relation to financial crime reporting and that they have read and understood the firm’s policies and procedures.
- Ensure that staff understand the firm’s risk-based approach in relation to financial crime.
- Ensure that role-based, competency-based training is carried out by all staff in relation to financial crime compliance, including but not limited to, knowledge of systems, controls, policies and a wider understanding of financial crime risks.
- Ensure that all staff have access to adequate annual training in financial crime compliance risks.
- Regularly collate and provide management information as necessary to the board or executive committee.
- Write an annual MLRO report providing an assessment of the financial crime prevention controls of the firm, with sufficient management information and recommendations for improvement.
- Make appropriate and meaningful recommendations for improvement on a regular basis where deficiencies have been identified in relation to financial crime prevention controls.
- Represent the firm and interact with all external agencies in relation to financial crime matters, including regulators and law enforcement agencies, and ensure any other third-party enquiries in relation to financial crime prevention, investigation or compliance are responded to in a timely manner.
- Support the Heads of Compliance in establishing and maintaining strong and effective relationships with key regulators including the PRA, FCA, Lloyd’s, CBI, CID, the relevant regulators, and financial crime regulatory agencies including HMT/OFAC/EU.
- Establish and manage close working relationships with key internal stakeholders, including the Executive Management, Boards and NEDs. This includes providing strategic-level financial crime compliance expertise and leadership to senior levels of management.
- Keep abreast of applicable sanctions, prohibition or advisory notices (such as Dear CEO letters). Ensure the business and staff are aware of sanctions and prohibitions by ensuring relevant training and regular communication notices are provided.
- Ensure that all reasonable requests for information by the regulator and law enforcement agencies are promptly responded to.
- Promote a culture of good conduct within the Financial Crime function by demonstrating and communicating the expected levels of behaviour and integrity.
FCA conduct rules – individual conduct rules:
- You must act with integrity;
- You must act with due care, skill and diligence;
- You must be open and cooperative with the FCA, PRA and other regulators;
- You must pay due regard to the interests of customers and treat them fairly; and
- You must observe proper standards of market conduct.
Senior Manager Conduct Rules (SMF17):
- You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively;
- You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system;
- You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively;
- You must disclose appropriately any information of which the FCA or PRA would reasonably expect notice; and
- A breach of these rules constitutes a regulatory breach and will be reportable to the regulator. It will also have to be disclosed on a reference to any future employers for at least 6 years following the breach
General
It is important that within all your interactions both internally and externally you adhere to Beazley’s core values - Being Bold, Striving for Better, and Doing the Right Thing as they contribute to an internal environment of teamwork and promote a positive brand image and experience to our external customers." We also expect Beazley employees to:
- Comply with Beazley procedures, policies and regulations including the code of conduct
- Undertake training on Beazley policies and procedures as delivered by your line manager, the People & Sustainability or assurance teams (compliance, risk, internal audit) either directly, via e-learning or the learning management system
- Display business ethics that uphold the interests of all our customers
- Ensure all interactions with customers are focused on delivering a fair outcome, including having the right products for their needs
- Comply with any specific responsibilities necessary for your role as outlined by your line manager, the People & Sustainability or assurance teams (compliance, risk, internal audit) and ensure you keep up to date with developments in these areas. This may include, amongst others, Beazley’s underwriting control standards, Beazley’s claims control standards, other Beazley standards and customer relationship management
- Carry out additional responsibilities as individually notified, either through your objectives or through the learning management system. These may include membership of any Beazley committees or working groups
Personal Specification:
Essential Criteria
- Proven financial crime expertise, preferably with a strong understanding of the Lloyd’s market and framework;
- Regulator relations experience in an insurance-related and/or financial services company/organisation.
- Expert knowledge of financial crime regulation, policies and procedures, particularly UK/EU/UN/OFAC Sanctions regimes, the Economic Crime and Corporate Transparency Act (ECCTA), the UK Proceeds of Crime Act Section 7, FCA SYSC Handbook 6.3, FCA Financial Crime Guide Parts 1 & 2, UK Bribery Act, UK Fraud Act, JMLSG Guidance, and Suspicious Activity Reporting.
Education and Qualifications
- Degree level educated; and/or
- Relevant professional qualification and experience
Knowledge, Experience and Skills
- Ability to build strong partnering relationships with a wide range of stakeholders
- Ability to interact professionally and with credibility and manage expectations of senior management and key stakeholders
- Proven management experience, with experience of leading / managing strategic change.
- Experience of dealing with financial crime regulatory agencies, including OFAC, OFSI & EU, in relation to sanctions issues
- Experience of working in a global and fast paced business environment is essential.
- Experience of reporting to and presenting to boards and committees
- Proficient in Microsoft 365 apps
Aptitude and Disposition
- Strong leadership and people management skills
- Application of risk-based judgement
- Maintaining confidentiality, diplomacy and discretion
- Influencing and trusted advisor
- Flexible
- Energetic, enthusiastic and positive
- Self-motivated with the ability to work autonomously
- Highest degree of integrity/discretion
- Strong written and verbal communication skills
- Analytical
- Attention to detail, with ability to see bigger picture
- Ability to challenge, negotiate with, influence and persuade both internal and external parties
