Purpose Of The Role
Sitting within the Ardonagh Group’s central Risk and Compliance function, the Ardonagh Group Head of Financial Crime supports the Group Financial Crime Director in the design of a proportionate financial crime framework. This framework is primarily focused on Sanctions and Bribery & Corruption, which is due to the extra-territorial reach of both US and UK legislation impacting globally, and that platforms are fully aware of any additional requirements that they must comply with. The framework is to be appropriately structured through a Financial Crime Policy, Sanction and B&C Business Standards and associated Standard Operating Procedures (SOPs).
The Head of Financial Crime will primarily be aligned with Sanctions and will provide subject matter expertise to Platforms/ segments through guidance and training, whilst playing a lead role in ensuring that before acquisitions are completed that the M&A teams have mitigated the risk of sanctions.
Although predominantly Sanctions focussed, the Head of Financial Crime must have a detailed knowledge of other applicable financial crime risks: bribery and corruption; money laundering; fraud; and facilitation of tax evasion.
Key Role Accountabilities
- To design a robust Sanctions screening framework, commensurate with a diverse, US-owned insurance broking group, subject to OFAC and HMT Sanctions requirements
- Provide Sanction SME knowledge to Platforms
- Oversee the response to sanction incidents occurring within a Platform and to lead any Group-wide coordination required
- Produce and update the content of the Sanction Business Standard & SOPs
- Provide support to the M&A teams by managing the GFC elements of the M&A Pre-Completion Sanctions Screening
- Provide support to Platforms when new challenges are identified and assist in providing solutions for Platform to implement to mitigate their sanctions risk exposure
- Update annual all-staff ‘sanctions’ training
- Oversight BAU Alert Review
- Review Tier 2 and 3 (where escalation required by Platforms) for Sanction Escalations (& Group Financial Crime Director with Tier 1 escalations)
- Provide SME sanctions expertise to Group R&C System team, who lead LexisNexis interaction
- Promote the importance and profile of financial crime compliance across the Ardonagh Group
Qualifications & Experience
- Degree and/or appropriate financial crime qualification (e.g. ICA Diploma in Financial Crime)
- Data management / systems knowledge
- Previous detailed expertise of sanction screening systems
Person Specification
- Leadership - provision of Group-level direction and leadership, setting the ‘tone from the top’ for the management of financial crime risks, and raising the profile of financial crime compliance.
- Influence - displaying gravitas and building strong buy-in from the business to enable the key delivery of financial crime compliance systems, controls and processes.
- Adaptability - being able to adapt approaches, if required, for the diversity of business conducted within the Group, and the differing scales and business models.
- Communication - excellent communicator with exceptional inter-personal and influencing skills, both verbal and written.
- Building Relationships - ability to communicate effectively at all levels within compliance and business units, including senior management, and drive action across the Group.
- Developing self and others - ability to work collaboratively including within different business platforms, and to lead by example to support and mentor business financial crime representatives.
- Thriving through change - lateral thinker with the ability to interpret and solve complex issues in a rapidly changing business environment, ability to think proactively and come up with ideas for enhancement.
- Commercial awareness - awareness of operational risks and the ability to understand the impact of financial crime risks on business policies and procedures, particularly in relation to insurance broking and underwriting.
- Technical skills - Excellent knowledge of financial crime compliance risks and good practice in managing them, with the ability to take commercially sound decisions based on knowledge and experience.
- Systems experience - Experience working with Sanctions compliance platforms including assisting with the implementation and operation of automated Sanction Screening tools.