UK Head of Compliance

  • Coinbase
  • London, England
  • Aug 03, 2018

Job Description

Back To All Jobs UK Head of Compliance
London, England

 

The UK Head of Compliance will operate under delegated authority from the Board and have overall responsibility for the establishment and maintenance of effective anti-money laundering (AML) and counter-terrorist financing (CTF) systems and controls. The UK Head of Compliance will be formally appointed by the Board as the MLRO, be a member of senior management and will report directly to the Board. The individual will be based at the UK Head Office.
Responsibilities: Establishing AML and CTF systems and controls
  • Maintaining and developing the risk based approach to AML and CTF arrangements - carrying out regular assessments of the adequacy of systems and controls to ensure that risks are managed effectively.
  • Overseeing the implementation of appropriate AML and CTF policies and procedures, including the operation of the risk-based approach.
  • Determining the level of resources required to execute appropriate AML and CTF policies and procedures.
  • Reviewing the output from the suspicious activity monitoring processes.
  • Ensuring that AML and CTF requirements are considered as part of the development of new products, or service changes.
  • Obtaining board approval for significant process changes.
  • Ensure that policies and procedures are accurately documented in the AML Manual which should be available to staff and used to guide training.
  • Ensure that the Board are kept informed of the money laundering risks posed by the business and its activities, and how these are managed and mitigated.
  • Reporting to the Board on a regular basis detailing the operation and effectiveness of the systems and controls used to combat financial crime.
  • Documenting and ensuring that any actions recommended by the Board are implemented.
  • Arrange and assist with regulatory visits and audit inspections.
Maintaining relevance of the AML systems
  • Regularly reviewing developments in applicable legislation and guidance (domestic and international where the business is involved).
  • Ensuring that policies are updated to meet changing regulatory and business requirements.
  • Ensuring that the operation of systems and controls are monitored and that they implement policy.
  • Maintaining up to date AML documentation.
  • Ensuring that relevant staff are provided with AML and CTF training appropriate for their position (frequency and content) and that all new staff receive training within the specified period. Ensure that training materials remain up-to-date and relevant to the business.
Reporting suspicious activity
  • Maintain an internal reporting process for receiving internal Suspicious Activity Reports (SARs).
  • Investigating internal SARs, using all available resources.
  • Deciding, following investigation, whether the internal report gives rise to knowledge or suspicion or reasonable grounds for knowledge or suspicion and submitting an external SAR to the National Crime Agency (NCA) where appropriate.
  • Documenting the reasons for not submitting an external SAR to the NCA where an internal report has been made, considered and deemed not to be suspicious.
  • Ensure that relevant records are retained for the prescribed periods.
  • Where required be the main point of contact for law enforcement officials.
Requirements:
  • The emphasis of this position is on developing, operating and maintaining systems and controls to prevent the firm's products and services being used for the purposes of financial crime and to meet reporting requirements
  • Minimum 5 years of experience in financial and/or compliance related business functions
  • Experience in developing and administering internal controls and processes
  • Ability to work collaboratively with a broad range of business functions, with an emphasis on senior management, is essential
  • A demonstrated ability to work with diverse groups of people is required
  • A willingness to take personal legal responsibility for the prevention of financial crime is essential
Preferred:
  • A professional compliance, or financial qualification, and membership of a recognized professional body, would be advantageous but not a pre-requisite

We are an equal opportunity employer and value diversity at our company. We do not discriminate on the basis of race, religion, color, national origin, gender, sexual orientation, age, marital status, veteran status, or disability status.
Privacy Notice and Consent for New Applicants
The General Data Protection Regulation (GDPR) regulates the way that we manage the data of job applicants. During this early phase of the application process, CB Payments Ltd (CB Payments) will be gathering and processing personal information (your data) in order to assess your suitability for the role in which you have applied. If you are unsuccessful during any point of this process then we are legally required to keep your data on file, for a period of time. We will keep your data in order to comply with employment law obligations only and for no longer than obligated to do so.

Under GDPR, we need your consent to process your application. With this form, we are providing you with notice on how your data will be processed as part of the application procedure. By signing this form, you are agreeing to our use and processing of your data as required.
Data controller details
CB Payments is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:

CB Payments Ltd (Coinbase)

CB Payments Ltd
9th Floor 107
Cheapside, London, United Kingdom
EC2V 6DN

Email -  myprivacy@coinbase.com
Data protection principles
In relation to your personal data, we will:
● process it fairly, lawfully and in a clear, transparent way;
● collect your data only for reasons that we have stated in this document;
● only use it in the way that we have told you about;
● ensure it is correct and up to date;
● keep your data for only as long as we need it; and
● process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed.
Types of data we process
We hold many types of data about you, including:
● your personal details including your name, address, date of birth, email address, phone numbers;
● biological sex;
● interview transcript/notes; and
● information contained within your CV including references, education history and employment history.
How we collect your data
From the start of this process we will begin to gather information about you. This includes the information you would normally include in a CV or a recruitment cover letter, or notes made by our Talent recruiting team during a recruitment interview.

In some cases, we will collect data about you from third party employment agencies, this information will only be passed to us from the employment agency upon your consent.

Personal data is kept in personnel files or within CB Payments HR third party business systems and IT systems. The access to these systems is limited to those job roles where it is essential to access your records.
Why we process your data
The law on data protection allows us to process your data for certain reasons only, the reasons relevant to you during this process are:

● in order to carry out legally required duties;
● in order for us to carry out our legitimate business interests; and
● to protect your interests.

All processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first two reasons set out above to process your data. We need to collect your personal data to assess your suitability for the advertised role.

We also need to collect your data to ensure we are complying with legal requirements such as:

● making reasonable adjustments for disabled employees; and
● tracking our fair employment process.

Special categories of data
Special categories of data include:
● health;
● sexual orientation;
● race;
● ethnic origin; and
● religion.

We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:

● you have given explicit consent to the processing;
● we must process the data in order to carry out our legal obligations; and
● you have already made the data public.

We will use your special category data:

● for the purposes of equal opportunities monitoring (as is our legal obligation); and
● to determine reasonable adjustments (as is our legal obligation).

We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we will ask for your consent to gather the information in the first place. You will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld, in the context of special data. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented GDPR compliant processes to guard against such.

Where we share your data with third parties, we provide written instructions to them to ensure that your data is held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it. If unsuccessful during the application process we will keep your personal details, interview notes and your CV details, is kept for 12 months or as long as is necessary to comply with applicable immigration law (whichever is shorter).

Successful applicants will be provided with an employee privacy notice as part of the on-boarding process.
Providing Consent
CB Payments is committed to complying with the GDPR. You are entirely in control of your decision to give consent to our use of your data as requested in this form. You do not need to give consent. However, in order for CB Payments to assess your credentials you will need to supply consent in order for us to process your application.
Withdrawing Consent
You have the absolute unrestricted right to withdraw your consent at any time. We will stop processing the data for which you have withdrawn your consent. Please note however, we must keep some personal data in order to comply with employment regulation.
Change in Purpose
If the purpose of using the data for changes, we will seek new consent, setting out the new purpose. You can decline to give your consent, with no repercussions. Consent can again be withdrawn at any time once given.
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO here: https://ico.org.uk/ if you are located in the United Kingdom, or to your local data protection authority.
Data Protection Officer
CB Payment's Data Protection Officer is Lydia Lavender. Contact details are:

myprivacy@coinbase.com