Manager, Anti-Financial Crime Oversight, Europe
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Job Description
Who we're looking for
We are seeking an Anti-Financial Crime Oversight Manager to join our Luxembourg based Financial Crime Compliance Oversight team. This role provides independent second line oversight, challenge and advisory support across key financial crime risk areas and delegated control arrangements, helping to ensure effective risk management, regulatory compliance and governance across Schroders' European Asset Management business.
About us
Schroders is a global investment manager which provides active asset management, wealth management and investment solutions. We aim to provide excellent investment performance to clients through active management. We serve a diverse client base that includes pension schemes, insurance companies, sovereign wealth funds, endowments, foundations, high net worth individuals, family offices, as well as end clients through partnerships with distributors, financial advisers, and online platforms.
Established in 1804, we have around 5,500 people across 36 global locations. Schroders' success can be attributed to its diversified business model, spanning different asset classes, client types and geographies.
Team Overview
The Europe Anti-Financial Crime Oversight team operates as part of the Group Financial Crime Compliance function, providing comprehensive oversight across Schroders business in Europe. This function serves as the central control for safeguarding Schroders against exploitation by illicit actors by establishing group wide financial crime policies and risk frameworks designed to meet regulatory obligations while protecting Schroders reputation. The role is based in Luxembourg.
Role Purpose
Reporting into The Head of Anti-Financial Crime Oversight – Europe, the Anti-Financial Crime Oversight Manager (Delegation) will support the delivery of second line of defence financial crime compliance oversight for Schroders Asset Management business lines across the Europe region, with a focus on the risks associated with the delegation/outsourcing of Anti-FC controls.
The role will provide advice, challenge, assurance and governance support across key financial crime risk areas, including anti-money laundering, counter terrorist financing, sanctions, fraud, bribery and corruption, tax evasion facilitation prevention, and proliferation financing, as well as key aspects of the delegation framework.
The role will support the Head of Anti-Financial Crime Oversight – Europe and the Local Money Laundering Reporting Officers (“LMLROs”) across the region in preparing and, where required, presenting FC Compliance reports, completing risk assessments, submitting regulatory reports, responding to authority requests, coordinating SIM EU input for on-site regulatory inspections and internal or external audits, designing or assisting in the development of FC Compliance Assurance and European business oversight plans, carrying out assurance over first line anti-financial crime controls, and monitoring of AML activities and reporting performed by SIMEU branches.
The role may also include acting as proxy for the Head of Anti-Financial Crime Oversight – Europe during periods of absence, where required, and taking on RC mandates [1] and/or MLRO responsibilities for investment funds managed by SIMEU (the “Funds”).
What you'll do
1. Financial sanctions advice, escalation and issue management
- Provide ongoing advice and guidance to senior management and first line functions on delegation related matters, including supporting the management of delegation-related queries and escalation channels.
- Collaborate with specialist teams and key stakeholders as required.
- Review delegation related control breaches and support assessment of root cause, containment, client impact, where relevant, and remediation actions as necessary.
2. Oversight of delegation framework
- Ensure the provision of ongoing second line oversight, opinions, and advice on delegation-related aspects escalated by the first line of defence / LMLROs, including onboarding of new delegates, delegation contracts, procedures, delegates’ initial and ongoing due diligence, the Business’ oversight of delegated Anti-FC controls.
- Maintain an Outsourcing Matrix on the Anti-FC tasks delegated by SIM EU to various categories of delegates: Transfer Agents, Distributors, Investment Managers, entities of the Schroders Group.
- Support the development and application of risk-based escalation criteria for delegation-related queries, ensuring that first line ownership is maintained and second line review is appropriately targeted.
3. Regulatory reporting and external obligations
- Provide support, as necessary, of annual, ad hoc and periodic financial crime regula