Diary of a consultant Compliance Officer, by Melissa Bradford26.02.2019
I work a full time compressed week over four long days Tuesday to Friday, so Monday is my day off. Although having remote access on my phone means I can still keep in the loop with things and respond to anything urgent.
Today started off with a visit to a Private Bank to work through their compliance monitoring programme, whilst producing a summary report for the Head of Compliance to review and consider for each area reviewed. At midday I have a Board meeting with one of my Investment Licensees, the focus was largely on the Handbook and the required changes and deadlines. In the afternoon I am invited to attend a new business committee meeting to give my vote on a new piece of high risk business for one of the Fiduciary firms I work with. My client visits finish by 3 pm so I am able to have a catch up on my emails.
I don’t have my first client meeting until 10am, so I start the day by reading through my google alerts and compliance blog updates on various websites. The first visit is at an intermediary firm of predominantly Financial Advisors. I spend the next 2 hours reviewing the new business files and periodic reviews which appear to be in order. To conclude my visit I review the various registers and logs to check that all training, gifts, PEPs, complaints and breaches are all logged and notified to the regulator if applicable. Over lunch, me and a couple of colleagues discuss the required updates to our in-house Compliance Manual and training slides following the changes to the Handbook. My final appointment is with an Investment Licensee for whom I act as CO and MLRO, the MD is looking for my advice on a possible derogation request to the Commission. After putting our Heads together and a few tweaks along the way, we submitted a request to the regulator outlining the rationale for the derogation request.
This morning begins with a regulatory seminar at St. Pierre Park where I see a few ex colleagues, so it was nice to catch up with them at the end. It’s clear from chatting to other compliance colleagues that everyone in the sector has the similar view and doing their best to keep on top of the ever changing regulation. Whilst catching up with one ex colleague he mentioned that they were looking for a part time Compliance Officer and if I knew of anyone. I explained about my role as a consultant and how this route may be more appropriate for their requirements and handed over my business card for their Head of Compliance. The afternoon involved a visit to my fiduciary client to review some high risk files, ensuring enhance due diligence is held and risk ratings are appropriate and commensurate with the risks posed. I end the day with a conference call to my colleagues in the Jersey office who are assisting with a remediation project for one of my clients, having just completed a similar exercise in Jersey it was useful to draw on their experience.
Today starts of well with bacon rolls in the office and our compliance team meeting, which gives us all a good steer of the latest developments and each other’s work loads. I have a weekly visit at one of my investment licensees, the focus is on writing up my Board Reports for the impending Board meeting. In the afternoon I attend a visit to a fiduciary client to have a catch up with the MLRO to discuss certain matters and sign off some new business. I also spend some time with the Trust Officers to run through a complex trust structure for guidance with CDD. After a long week, my Friday finished around 4.30 pm and the boss takes us all for a well-earned alcoholic beverage.