Compliance Officer & Head of AML

The role provides independent advice, oversight and challenge to Branch management and business areas and acts as a key point of contact for Compliance, AML/CFT and financial crime matters.

Key Responsabilities:

1. Compliance Framework and Governance

• Lead and coordinate the Compliance function of the Italian Branch, ensuring its independence, authority and effectiveness.
• Develop and maintain the Branch Compliance Risk Assessment and prepare the Annual Compliance Plan using a risk-based approach.
• Ensure that Group policies and procedures are appropriately implemented and adapted to Italian regulatory requirements.
• Monitor regulatory developments and assess their impact on the Branch's activities, products, processes and controls.
• Provide independent advice and effective challenge to the Country Manager, management and business areas.
• Report material compliance risks, incidents, control weaknesses and remediation progress to Branch management and the relevant functions.
• Participate in the relevant Branch management and internal control committees, as applicable.

2. AML/CFT and Financial Crime

• Oversee the Branch AML/CFT framework in accordance with Italian and European requirements and Group standards.
• Develop and maintain the AML/CFT Risk Assessment and related policies, procedures, systems and controls.
• Oversee customer onboarding, KYC, customer risk classification, Customer Due Diligence and Enhanced Due Diligence.
• Provide advice and oversight for higher-risk customers, politically exposed persons, complex ownership structures and higher-risk jurisdictions.
• Oversee AML alerts and transaction monitoring, including Trade Finance activities.
• Assess potentially suspicious activity and ensure appropriate analysis, escalation and reporting to the UIF where required.
• Oversee financial sanctions controls, including customer and transaction screening.
• Coordinate and oversee outsourced AML/CFT activities while ensuring that accountability remains with the Branch.

3. Compliance Monitoring and Regulatory Compliance

• Develop and execute a risk-based Compliance Monitoring Plan.
• Perform or coordinate second-line monitoring and testing and assess the design and effectiveness of compliance controls.
• Identify weaknesses, agree remediation plans with responsible areas and monitor implementation.
• Monitor compliance with the Code of Ethics and policies on anti-corruption, conflicts of interest, third-party due diligence, data protection and prevention of criminal offences.
• Support regulatory inspections and internal and external audits and monitor resulting recommendations.

4. Regulatory Reporting and Authorities

• Act as a key Compliance and AML contact with Banca d'Italia, the UIF and other competent authorities within the responsibilities assigned to the role.
• Coordinate Compliance and AML regulatory reporting applicable to the Italian Branch.
• Prepare periodic and annual Compliance and AML reports for Branch management, governance bodies.
• Coordinate responses to regulatory requests and support regulatory examinations and inspections.
• Escalate significant regulatory matters promptly to Branch management and Head Office.

5. Advisory and Coordination

• Provide Compliance and AML advice to Business, Operations and other Branch functions.
• Review new products, services, relevant transactions, outsourcing arrangements and material process changes from a Compliance perspective.
• Work closely with Risk Management, Legal, Operations, HR, IT, Internal Audit and the relevant functions.
• Coordinate with Compliance and AML teams to ensure consistency between local requirements and Group standards.

6. Training and Compliance Culture

• Develop and coordinate the Annual Compliance and AML Training Plan.
• Ensure that employees receive appropriate induction and periodic training on Compliance, AML/CFT, sanctions, ethics and conduct.
• Maintain appropriate records of content, attendance, completion and assessment results.
• Promote a strong culture of integrity, accountability and regulatory compliance throughout the Branch.