Financial Crime Compliance, VP
Description About this role
BlackRock's Global Compliance Department protects BlackRock's reputation and provides advice to the business focused on ensuring the protection of our client's best interests. The department is a dynamic environment with the team focused on understanding evolving business strategy, challenging and advising on the impact of regulation in our business, with the objective of:
- Actively participating in business decisions to champion our clients' interests and assist the business in translating Compliance into their daily work and decision making;
- Putting client interests at the center of everything we do;
- Cultivating and enhancing BlackRock's compliance culture;
- Providing thought leadership on the impact and implementation of regulation to our business and to the market; and
- Developing and fostering excellence within the Compliance team
An exciting opportunity has arisen for a VP to join our team, based in Luxembourg, reporting to the Luxembourg Financial Crime Lead. The individual in this role will advise on financial crime risks, including money laundering and terrorist financing, sanctions, bribery and corruption and fraud. Subject matter expertise in Luxembourg and EU Financial Crime law and regulation is essential. The role will primarily focus on BlackRock's alternative investments business in Luxembourg, where there are a number of funds, for which the successful candidate will take on the responsibility of MLRO.
The successful candidate will work with internal and external stakeholders to implement BlackRock's Global AML Programme, alongside local Luxembourg requirements in relation to various fund types and business activities. This includes working directly with Senior Management and Boards, providing advice, metrics, and reporting. Engaging with operations teams and service providers, such as Transfer Agents, as well as the CSSF and other relevant authorities. Additionally, as a member of EMEA Financial Crime Compliance there may be occasions where the successful candidate is requested to support activity beyond Luxembourg and work with work with the broader EMEA Financial Crime team, based in London, Luxembourg, the Netherlands and Budapest and also members of Legal and Compliance, the business and operations across EMEA, APAC and the Americas. Key Responsibilities:
- Work closely with the Luxembourg Financial Crime Lead to enhance the financial crime risk management framework in Luxembourg, with particular focus on the alternative investment business, in relation to managing the risks of money laundering sanctions, fraud and bribery and corruption ("the four risks") in Luxembourg, including writing and maintaining country and fund specific policies and procedures and undertaking relevant risk assessments;
- Take on the MLRO responsibility for BlackRock's Luxembourg domiciled alternative investment funds;
- Coordinate with the Financial Crime colleagues as necessary on the risk framework priorities and assist in the oversight of required regulatory change management processes.
- Ensure completion of annual AML Risk Assessments related to the Luxembourg domiciled alternative funds, in line with BlackRock's Global methodology and incorporating any additional Luxembourg or business specific aspects.
- Support relevant audits, regulatory visits and examinations for financial crime in Luxembourg generally and in particular in relation to the relevant alternative investment funds.
- Produce regular management information for the consideration by the relevant members of Financial Crime Compliance and boards and committees, including structured quarterly reporting and appropriate annual reports on the four risks.
- Provide clear technical advice, guidance and training on all four risk areas to relevant members of the business both in Luxembourg and where relevant beyond, including Senior Management and Board members.
- Assist in the establishment and maintenance of a monitoring program in Luxembourg, which provides ongoing review and monitoring of the financial crime risks associated with Transfer Agents and Fund Distribution Partners, with particular focus on the alternative investment funds.
- Alongside other team-members provide a point of contact for financial crime queries related to complex transactions and high-risk client onboardings, especially where related to the alternative investment funds.
- As required provide advice and approvals in relation to PEPs and other heightened risk factors encountered during onboarding.
- Partner with Legal to assist in Fund oversight and compliance with requirements relevant to the four risks.
- Ensure the active identification, response and/or escalation of risks as appropriate.
- Assist with the preparation and presentation ad-hoc and regular reports to fund boards and senior management, as well for the EMEA and Global Heads of Financial Crime and other senior members of Legal and Compliance.
- Form strong relationships with key individuals within the business, compliance and operations and external service providers.
- Provide support to the Luxembourg Financial Crime Compliance Lead.
This is a new role within a recently established and growing specialist financial crime compliance team within Luxembourg. Athough there is an existing framework in place, there is an opportunity for the successful candidate to help develop the local financial crime programme to better meet BlackRock's policy and local regulatory requirements in support of the needs of a dynamic and growing global business. The individual will gain an appreciation of BlackRock's operations in Europe and our global approach to managing regulatory and compliance risks in the EU. This role will have interaction with senior Business, Compliance and Legal stakeholders. It is anticipated that the successful candidate will be the MLRO for a number of Luxembourg domiciled alternative investment funds and in future is likely to also have people management responsibilities. Knowledge/Experience:
The successful candidate should have:
- At least 6+ years of experience in Financial Crime Compliance risk management at a financial institution or consulting firm; experience working as Financial Crime specialist and MLRO within asset management and specifically Alternative investment funds is preferable but is not essential.
- Strong knowledge of Luxembourg Financial Crime regulations, financial services, and regulatory trends that impact the Asset Management industry, its products and/or its underlying institutional and corporate client base.
- Experience of policy and procedure writing and be confident in performing risk assessments and undertaking monitoring and testing.
- A strong understanding of the requirements of a Luxembourg AML program and EU regulatory requirements, and the role of transfer agents, distributors and other third parties is necessary.
- Strong working knowledge of Luxembourg AML and Sanctions laws and regulations such as the Law of 12 of November 2004 as amended, the CSSF 12-02 as amended, the Grand-ducal regulation of 29 October 2010; an understanding of Fraud and Anti-Bribery and Corruption is a plus.
- Experience of managing and /or participation in supervisory exams would be an advantage.
- A proactive approach to considering business issues, identifying areas of improvement and enhancement, including the automation of processes
- Excellent written and verbal communication, judgment and business partnership skills, including working as part of a global team in a fast-paced environment.
- Previous experience as an MLRO or Deputy MLRO is a valuable advantage.
- Experience of people management in a corporate setting would be beneficial.
- English fluency is a requirement; French is an advantage.
To help you stay energized, engaged and inspired, we offer a wide range of benefits including a strong retirement plan, tuition reimbursement, comprehensive healthcare, support for working parents and Flexible Time Off (FTO) so you can relax, recharge and be there for the people you care about. About BlackRock
At BlackRock, we are all connected by one mission: to help more and more people experience financial well-being. Our clients, and the people they serve, are saving for retirement, paying for their children's educations, buying homes and starting businesses. Their investments also help to strengthen the global economy: support businesses small and large; finance infrastructure projects that connect and power cities; and facilitate innovations that drive progress.
This mission would not be possible without our smartest investment - the one we make in our employees. It's why we're dedicated to creating an environment where our colleagues feel welcomed, valued and supported with networks, benefits and development opportunities to help them thrive.
For additional information on BlackRock, please visit careers.blackrock.com | www.blackrock.com/corporate | Instagram: @blackrock | Twitter: @blackrock | LinkedIn: www.linkedin.com/company/blackrock
BlackRock is proud to be an Equal Opportunity and Affirmative Action Employer. We evaluate qualified applicants without regard to race, color, national origin, religion, sex, sexual orientation, gender identity, disability, protected veteran status, and other statuses protected by law.
BlackRock will consider for employment qualified applicants with arrest or conviction records in a manner consistent with the requirements of the law, including any applicable fair chance law.