Head of Public Side Advisory

Purpose of Job

Compliance Advisory is one of the key functions in ensuring the SMBC Group in the EMEA (the Bank) is compliant in meeting regulatory expectations in complying with all relevant laws, rules and regulations which apply to the Bank.

Compliance is required to protect the Bank and their employees from regulatory censure and ensure positive outcomes for its customers and markets by enabling the business to meet its risk preferences and statements relating to compliance risks and embed a compliance culture in the firms’ day-to-day activities.

To support the Bank’s sustainable growth strategic approach, in anticipating new regulatory direction and new product development and utilising extensive banking experience to achieve positive customer outcomes and proactive regulatory engagement, the Head of Public Side Advisory is responsible for providing advice and guidance to the Front, Middle and Back Offices as well as ensuring a comprehensive policy framework is maintained across the group entities on a multi-product basis for the Public Side business activity.

To this end, the Head of Public Side Advisory is responsible for a number of complex and highly technical product areas representing significant risk including Foreign Exchange, Money Markets and Derivatives, Benchmarks, Regulatory Infrastructure, Trade & Transaction Reporting, Fixed Income and Equities. These responsibilities are predominately in London but also require the provision of advice to other offices in the EMEA region including Frankfurt and AGDM (where relevant) as well as liaising with Americas, Hong Kong and Tokyo Head offices on Public Side compliance issues and remote booking arrangements.

This role-holder is a member of the Compliance senior leadership team.

Background

• Internally, the role requires close collaboration with senior management including the Regional Chief Compliance Officer, CRO, COO, General Counsel and CEOs and colleagues in other functions, particularly FX, Money Market, Treasury Derivatives, Fixed Income, Equities desks as well as the Planning department, Operations and Risk in providing advice and guidance.
• The role holder must liaise closely with these areas in addition to Compliance Private Side Advisory, Compliance Training and Communications, Compliance Monitoring & Surveillance, Regulatory Affairs, Conduct Analytics, Policy & Governance and Financial Crime on product specific matters.
• The role holder will support the universal bank initiative with the integration of functions and a control framework that is as efficient as possible and promotes sharing “group and global” best practice.
• The role requires oversight of the Benchmarks Compliance Officer’s liaison with Internal and external Audit who are required to complete extensive audits on the bank as a benchmark contributor as well as oversight of the management of the critical outsourced benchmarks surveillance provider.
• The role is an important external-facing role, potentially requiring direct engagement with regulators and other external authorities as the main point of contact for Public Side related queries arising from the FCA, Benchmark Administrators and External Auditors as well as representing the firm at key industry associations.
• The role holder will need to understand and advise senior management and other stakeholders upon significant and far-reaching regulatory developments undertaken by regulators in the UK, Europe, USA, Hong Kong and Japan including Market Abuse including Benchmarks, Conduct risk framework, MiFID II, MIFIR and EMIR refit.
• The role requires expert judgment and a high level of accountability to escalate communications, investigations and reporting of suspicions of manipulation, attempted manipulation or collusion to the FCA relating to benchmarks and other financial instruments.
• Supervision of investigations relating to conduct, whistleblowing or complaints concerning the accuracy or integrity of the contributing bank’s submission, including the logging, review and follow-up of all breaches and complaints or any other relevant matters.
• Management of a team of compliance professionals including skills development.
• Ownership of MiFID II, MIFIR, EMIR and Benchmarks related Policies.

Facts / Scale

• High impact responsibility given direct engagement with regulators, board and senior management.
• Management of a team of Subject Matter Experts in Public Side Advisory.
• Providing expertise on major complex projects that have significant group level impact in the EMEA and globally including MiFID, EMIR, IBOR Discontinuation, Transaction and Trade Reporting, Surveillance, Securities Financing Transactions Regulation.
• This role is one of the key functions in ensuring that the entities are compliant in meeting regulatory expectations in complying with all relevant laws, rules and regulations which apply across the EMEA region (including remote booking offices worldwide).
• Underlining the importance of providing the correct advice and making the right judgments in the capacity of this role is the level of attention from the regulators. In March 2019, (UBS) was fined £27,599,400 by the FCA for failings in transaction reporting and in April 2019 Goldman Sachs was fined £34,344,700 for their failings in transaction reporting. The consequences of applying the wrong judgment could be extremely serious for the organisation.
• The role holder is expected to lead projects and initiatives which involve all group entities and geographies globally.
• The role holder is responsible for provision of relevant services within the EMEA region based on the relevant Service Level Agreements for the Provision of Services.
• The role holder must promote harmonisation of the group regulatory approach on complex existing and new regulatory initiatives particularly as the universal banking model becomes fully adopted.
• The role holder must liaise with the EMEA Region Local Compliance Officers to co-ordinate Public Side compliance activities for better effectiveness and efficiency.
• Member of the senior leadership team within Compliance, contributing to strategy and planning.

Accountabilities & Responsibilities

• Obtain reasonable assurance that there are adequate documentation, procedures and resources to support benchmarks and investment products compliance supporting the universal bank model.
• Manage and develop the team members to ensure that all areas of responsibility are appropriately addressed, compliance skill-sets are adequate and ensuring that opportunities are fairly distributed amongst all colleagues, irrespective of background, race, disability, sexual orientation or gender identity with colleagues’ well-being at the fore to maintain a positive working environment.
• Promote the development and integration of Compliance Advisory systems and processes to facilitate the efficient and effective response to regulatory and business expectations for the universal bank, seeking to harness new technology and automation and embracing technological developments to reduce the reliance on manual controls, unaligned systems and tactical short-term solutions and improve operational efficiency.
• Drive proactive, efficient, effective and consistent responses to rapidly changing or divergent regulatory requirements, closely collaborating with the Regulatory Affairs Team, and to continue supporting business growth and the introduction of new products, services, customers and geographies.
• Cultivate a positive compliance culture across the Bank implementing proactive engagement with stakeholders and providing appropriate advice, instruction and influence where needed to mitigate the risk in specialised product areas.
• Develop and deliver training materials in collaboration with the CPD Education and Communications Team.
• Investigate any identified potential or actual breach of relevant rules and regulations and assist in reporting to senior management and the regulatory authorities and in rectifying the situation.
• Advise and provide guidance to relevant senior management (Regional Chief Compliance Officer, General Counsel, COO, CRO, CEO and Board Members) of significant issues and updates.
• As a senior member of staff, seek opportunities to take an active role in wider Group initiatives such as D&I and/or CSR.
• Be accountable for an effective Public Side compliance framework, working closely with stakeholders in the first, second and third lines of defence and flagging any concerns or issues.

Knowledge, Skills, Experience & Qualifications

• Recognised subject matter expert in MiFID II, MIFIR, EMIR and related products including FX, Money Market, Derivatives, Fixed Income, Equities and transaction reporting from an execution and/or advisory perspective.
• Demonstrated understanding of relevant existing and expected regulations for a universal bank.
• Experienced team manager
• Positive approach to providing solutions.
• Ability to multi-task and work well under pressure.
• Good communicator.