AML & Compliance Officer

Anti-Money Laundering and Counter Terrorist Financing (“AML/CTF”)

The Money Laundering Reporting Officer (MLRO) works closely with the Head of Group AML&CFT to establish, maintain and develop a robust and effective AML/CTF framework throughout the Japan covering the following business operations:

Retail Bureau de Change

Wholesale Cash Processing

• Conduct KYC and KYB due diligence (“CDD”) checks for retail customers and wholesale business partners, whilst maintaining appropriate records;
• Undertaking enhanced due diligence (“EDD”) where appropriate;
• Daily review, record keeping and where necessary the escalation of potential Sanction and PEP alerts;
• Conduct ongoing-monitoring of wholesale business partner business, including onsite visits;
• Receive internal Suspicious Transaction Reports (STRs), review and submit to the National Crime Agency (NCA), Head of Group AML& CFT and any other local regulator in a timely manner;
• Manage and oversight of SAR/STRs process within the Japan,
  Maintain a robust STR database, including the record keeping of all internal STRs, supporting documentation and evaluation evidence;
• Review record and where necessary submit STRs to the Japan FIU;
• Maintain accuracy within the sector specific AML Manuals for the Japan;
• Where requested, represent the compliance function when meeting external suppliers/partners;
• Assist the Group Internal Auditor prior to and during the annual AML/CTF internal audit
• Compiling Management Information (“MI”) for the monthly Compliance reports;
• Deal with AML/CTF queries and questions from across the Japan business;
• Assist with requests for information from law enforcement and other authorities; and
• Attending AML/CTF forums and groups as and when required.

Compliance risk analysis

• Responsible for the ongoing transactional monitoring of all business services, including record keeping maintenance and the investigation and review of any unusual trends or patterns;
• Coordinate the monthly complaints logs for the Region and review for any complaints that relate to possible staff fraud;
• Oversee the gifts & hospitality process;
• Assist in the investigation of suspected fraud/theft;
• Provide a monthly report on AML compliance to the Head of Group AML&CFT
• Compliance in the field of personal data protection and crime prevention.
• Know the regulations applicable to the subsidiary and ensure compliance with them, especially in the following key subjects:
  • Obligations established by the central bank or supervisory body (committees, reporting, etc.).
  • Obligations established in the main Manuals and Policies:
    • Code of Ethical Conduct
    • Money laundering prevention manual
    • Data Protection Policy.
    • Policy on the granting of powers of attorney.
    • Anti-corruption policy.
    • Operation of the Ethical Channel.
    • Respond to requests for information from the police and courts on fraudulent operations.
    • Ensure compliance with training plans and participate in them when required.
    • Attend internal audits and draw up the necessary action plans to implement the proposed improvements.
    • Actively participate in the definition of strategies and policies that contribute to improving the effectiveness of GE's Compliance programme.

General

• Review new developments within the country related to Global Exchange’s legal and regulatory requirements.
• Ensure that the management of updating policies and procedures within the Japan network is undertaken in an appropriate timeframe and with due consideration of local laws and regulation, and ensuring adoption of external audit recommendations.
• Liaise with the global audit team, taking ownership of audit planning within the Japan and the mitigation of any regulatory issues found during branch inspections.
• Participate in the development of new products/services and associated policies and procedures to ensure there are adequate policies and procedures in compliance with applicable laws and regulations before final design and implementation.
• Maintain a Compliance Training Program and materials to address policies and procedures, as well as all applicable laws and regulations as deemed necessary.
  Undertake periodical issue of compliance memorandums to staff regarding new developments in law/regulations, internal policy issues and other critical information regarding compliance issues.
• Help co-ordinate with external auditors and regulatory agency’s examiners during compliance examinations, act as primary examination contact, and furnish examiners with requested information to ensure that compliance issues are adequately addressed in connection with such audits.
• Maintain an Inventory of compliance resources and policies/procedures.
  Provide leadership as first point of contact for compliance within the Japan, building strong relationships with key internal stakeholders and external regulators and business partners.
• Any other ad hoc duties that may be required.