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Position Title: Policy Manager
Business Unit: Risk Managed Services, Org ID.
Product or Service:
Org ID is a key component of TR's Know Your Customer (KYC) Industry Solutions business. Org ID facilitates regulated entities' compliance with anti-money laundering (AML) laws and regulations. Org ID's focus is compliance with identify verification for legal entity clients. The Org ID service also completes identity verification for legal entity individual related parties.
The Org ID Policy Manager will assist the Global Head of Policy and Standards, Risk Managed Services in the development, maintenance, and oversight of the Org ID Policy, Customer Due Diligence Standards, Related Lists, Screening Policy and Monitoring Policy (collectively "the Policy"). The Policy Manager also will support the EMEA and North America Policy lead, Policy Maintenance & Governance Lead and Policy Operations Lead.
Main Responsibilities / Accountabilities:
Policy review and maintenance
- Research, analyse and stay current on existing and new global anti-money laundering (AML) and know your customer (KYC) laws and regulations through regulatory "horizon scanning" and other means
- Provide advice on global AML and KYC laws and regulations to Org ID teams
- Identify new client identification and verification laws and regulations and changes to existing ones, including emerging trends in these areas
- Map changes to AML and KYC laws and regulations, e.g., 4th EU AML Directive, to relevant Policy provisions
- Produce timelines of e.g. regulatory change with key milestones for implementation
- Produce relevant project plans and communications plans to address regulatory change in the Policy
- Support the Policy Governance Lead by:
- Recommending draft revisions/developments to the Org ID Policy to incorporate and address new and/or changing AML and KYC laws and regulations
- Communicating Policy changes to internal and external stakeholders
- Working with other Org ID teams to ensure agreed Policy changes are reflected in relevant standard operating procedures (SOPs)and technology systems
- Helping to manage the version control of the Policy
- Support the Policy change process with other Org ID teams
- Ensure lessons learnt from internal and external engagement on Policy are assessed and incorporated where appropriate in future Policy development.
Advice, guidance and support for internal and external stakeholders
- Work closely with other Policy team members including EMEA and North America Policy lead, Policy Maintenance & Governance Lead and Policy Operations Lead
- Support the Policy Operations lead in:
- Ensuring that Policy updates are correctly interpreted and cascaded to downstream/operational processes and systems i.e., correctly applied within the business
- Providing guidance to operations teams on Policy interpretation e.g., in creating and maintaining client profiles
- Providing input and periodic oversight to SOPs to ensure they are fit for purpose from a Policy compliance perspective
- Identifying recurring operational implementation issues and proposing solutions to address them
- Support the Business Development, client consultant and client experience teams in explaining and responding to queries regarding the Policy
- Support technology teams in:
- Review and implementation of Policy related changes to Org ID systems
- Review of implementation testing outputs from a Policy perspective
- Serve as a point of escalation for Policy related issues raised by internal and external stakeholders
- Analyze and respond to Policy and/or procedure queries from colleagues, subscribing financial institutions (SFIs) and other service users
- Engage with new SFIs to support service delivery activities including post implementation work
- Participate in and support Policy team members in preparation for the Policy Advisory Forum and Compliance Committee
- Produce fit for purpose presentation materials for meetings, conferences, seminars and training
- Provide Policy related training to internal and external stakeholders
- Design, develop and prepare materials for client-focused presentations.
The Policy Manager reports to the Policy Operations Lead and works closely with colleagues from the Org ID Policy team, other Org ID business units including Business Development, Client Consultants, Operations and Technology, and SFIs.
Essential Skills and Experience:
Successful candidates will be ethical, highly motivated, diligent, self-starters, team players and have the gravitas to engage with senior internal and external stakeholders. Successful candidates should have:
- Intellectual interest in legislative and regulatory frameworks
- Knowledge of AML, KYC and sanctions laws and regulations
- Experience of interpreting laws and regulations and translating them to Policy and operational requirements
- Business experience and analytical skills including:
- Analyzing complex issues and proposing alternative solutions to issues
- Analysing concerns/issues raised by stakeholders in multiple global locations
- Identifying solutions through creative thinking and goal-oriented research and analysis
- Amending policies and preparing guidance and procedures to implement changes
- Executing complex projects
- Building rapport and strong working relationships with internal and external stakeholders at all levels of seniority
- Developing consensus across disparate internal and external stakeholders
- Managing change with multiple stakeholders
- Liaising with dispersed teams
- Working with clients
- Working under pressure to meet tight deadlines
- Excellent written and oral communications skills including producing fit for purpose, targeted written communications, e.g., reports for senior management and guidance for operations teams and preparing and delivering AML and KYC presentations to internal and external stakeholders
- Excellent PowerPoint and Excel skills
Desired Skills and Experience:
- Working for a regulated financial institution
- Knowledge of client data and processes e.g., completion of KYC records
- Understanding of KYC on-boarding workflow platform e.g., GoldTier
- KYC utilities and/or managed service providers
- Familiarity with FATCA and related laws and regulations
- Familiarity with bribery and corruption laws and regulations
- Familiarity with data privacy laws and regulations
- Familiarity with project management principles
Education/ Certifications Preferred:
- Legal qualification
- ICA or ACAMs qualification to Diploma level in AML and/or KYC
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