- Permanent, Full time
- Schroders Investment Management
- Full time
Senior Specialist Due Diligence (AML/KYC)
Senior Specialist Due Diligence (AML/KYC)Team Overview
The Distribution Control Team is responsible for multiple key tasks within Schroders Europe, such as conducting Intermediary Due Diligence, Cross-Border Activity Control, Branch Oversight, and Distribution Monitoring Control.
Intermediary Due Diligence ("DD") includes gathering and analysing information to assess the risk of money laundering / terrorist financing in relation to intermediaries and distributors ("intermediary") prior to establishing distribution contracts with Schroders Europe to distribute, purchase or privately place investment funds. Particular relevance is made to the term "intermediary" as private individuals will be dealt with by the Transfer Agent. The Intermediary On-going Due Diligence is the process by which all the existing and established relationships are reviewed on a regular basis to ensure compliance with the latest Anti Money laundering laws and regulations, as well as with the internal policies and procedures in Luxembourg.
Cross-Border Activity Control ("CBAC") is defined as the conducting of business activity from one jurisdiction into another, with cross-border clients or with other third parties, with the intention, directly or indirectly, of marketing the "Schroders" brand, distribution or furthering distribution of Schroders products (pooled funds, structured products, etc.) or providing services such as discretionary or advisory. It also includes servicing existing clients, exploring business development opportunities and responding to requests from Cross-border Clients even when the contact was unsolicited by Schroders. Schroders Europe must remain compliant with applicable laws and regulations relating to the conduct of CBA, including the requirements around Anti-Money Laundering and Sanctions.
Branch Oversight ("BO") is the activity in place in order to ensure the robust oversight of Schroders European branches to mitigate any risks associated with the activity carried out by them. BO includes frequent interaction, ongoing support and monthly status meetings, and formal onsite meetings, if required. BO activity also covers documenting the procedures with branches to ensure that they provide specific data on a clearly defined timeframe to centralise and produce reports for the Board of Schroders Europe and the CSSF.
Distribution Monitoring Control ("DMC") is the control and monitoring of all distribution related matters, monitoring the client life cycle, keeping all existing databases up-to-date, and preparation of reports and KPIs.
One of the primary responsibilities of the Distribution Control team is carrying out Intermediary AML/KYC Due Diligence, which includes both initial Due Diligence and Ongoing Due Diligence. This also includes the assessment of the clients' operational model, fund distribution plans and behaviour, as well as all possible risks associated with such activities.
Key functions of the role
• Carry out intermediary DD by gathering information on potential intermediaries with whom the Company is considering entering into a contractual relationship and performing On-going DD on existing relationships in line with internal policies and procedures on a regular basis, via desk reviews and/or on-site inspections, where necessary;
• Perform the final control on the Due Diligence and Ongoing Due Diligence process to verify that all relevant documents have been received, are valid and correctly certified where relevant and in line with Schroders Europe policies and procedures;
• Ensure the DD document files are complete and records of performed DD, ODD and findings are clearly filed
• Verify and where required, complete the input of intermediary agreements, addenda, KYC/DD documentation and other documents in relation to an existing intermediary as well as any other relevant information into the appropriate database or spreadsheet;
• Prepare the intermediary KYC file for scanning once all controls are completed correctly;
• Organise and follow up on Ongoing Due Diligence files and actively participate in meetings and calls with potential and existing intermediaries, Client Service Managers (CSMs) or Sales Offices (SOs);
• Assist CSMs and our worldwide based SOs in their communication with investors with regards to Schroders Europe KYC requirements by providing, for example, an overview and clarification of internal policies and procedures, as well as clarifying the Luxembourg AML/CTF legal framework, legislation and relevant requirements;
• Perform internet research to gather open source information for due diligence purposes;
• Assist the Line Manager and team members on ad-hoc requests and any matters related but not limited to, the Distribution Control team's responsibilities, in particular preparation of reports and KPIs;
• Audits: Assist internal and external auditors on any questions in relation to Intermediary KYC and DD;
• Participate in team projects in relation to AML/CTF matters, upon request.
• Participate in establishment or update of team policies and procedures, when required.
• Good knowledge of the Luxembourg regulatory framework governing AML/CTF and Fund Distribution;
• Minimum 3-4 years' experience in the financial industry with exposure to AML matters;
• Team player, supportive of others, proactive;
• Decision maker, capable of taking initiatives and solution oriented mind-set;
• Diplomatic, excellent communicator, will have dealt directly with internal and external clients;
• Excellent organisational skills;
• Self-educating, curious, pragmatic;
• Able to multi-task, work under pressure with commitment to deliver under a tight deadline;
• Fluency in English (verbal and written);
• Knowledge of Microsoft Office, in particular Excel and Word.
• Knowledge of another European language would be an advantage (in particular French, Spanish, Italian).