Manager, Anti-Financial Crime Oversight, Europe (Delegation)

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Manager, Anti-Financial Crime Oversight, Europe (Delegation)

senior · Risk & Compliance

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 regulatory reporting, including applicable regulatory submissions as these relate to delegation of Anti-FC controls.
• Provide advice and guidance on delegation related topics to the first line of defence / LMLROs during external AML audit exercises.
• Provide financial crime responses to due diligence questionnaires and other external stakeholder requests where specialist Financial Crime Compliance input is required on delegation related topics. 
   

4. Delegation framework, policy and procedure oversight

• Provide support to the maintenance and development of the delegation framework, policy, and controls. 
• Maintain awareness of minimum standards, policy requirements and procedural expectations, ensuring business activity remains aligned to the wider delegation framework. 
• Provide support and assistance from delegation-related obligations' viewpoint into the maintenance of financial crime policies, standards and related inventories. 
   

5. Monitoring, assurance and oversight

• Provide support and guidance to LMLRO assurance over first line delegation key control processes, including thematic reviews, control assessments and oversight activity. 
• Review delegation-related control breaches and support assessment of root cause, containment, client impact where relevant, and remediation actions as necessary. 
• Triage identified delegation-related issues by severity, regulatory exposure and control weakness, ensuring appropriate ownership, deadlines and escalation routes are defined.
• Perform regular review of first line procedures to assess alignment with Group / local delegation policies, standards and regulatory expectations.
   

6. Screening and control oversight

• Review and assess delegation controls across the business to ensure effectiveness and assist in the enhancement of relevant processes, as required.
• Provide support and guidance and challenge over delegates’ name screening and alert management processes. 
• Provide support and guidance to LMLROs regarding escalated delegation matters where second line input is required following first line assessment. 
• Support, where required, the review of screening tools, rules, risk assessment and related control arrangements to ensure they remain aligned with policy and risk appetite expectations. 
   

7. Management information and governance reporting

• Conduct regular horizon scanning across EU authorities and regulatory developments in relation to delegation/outsourcing of Anti-FC controls, assess the impact of relevant regulatory developments on SIM EU and Schroders’ European business, and ensure timely updates of key developments to key stakeholders.
• Develop, prepare and, where required, present delegation-related management information (MI) for onward provision to senior management. 
• Maintain or support the financial crime compliance MI inventory and data lineage for relevant metrics, including delegates’ KRIs. 
• Ensure the provision of clear, risk-based commentary on delegation themes, incidents, issues, root causes, remediation progress and emerging risks for governance forums. 
• Support, where required, the development of briefing materials for business leaders, committees, Boards or management forums on delegation risk and trends. 
   

8. Risk assessment

• Support the annual financial crime risk assessment process, including local workshops, challenge sessions, evidence review and documented outputs where delegation-related inputs are required. 
• Provide input and review to risk assessment updates ensuring key risks, controls, issues and remediation actions relating to delegation risk are accurately reflected. 
   

9. Training and awareness

• Support, where required the design / delivery of mandatory, targeted and ad hoc delegation-related specific training. 
• Support the maintenance and update of induction training material and role-based training content covering the delegation risk. 
• Support escalation of non-completion of required training attendance where relevant, particularly for higher-risk roles. 
• Issue or support the production of targeted delegation-related learning briefings following incidents, typology changes, regulatory developments or control lessons learned as it relates to delegation. 

RC mandate responsibilities

As appointed RC of applicable Luxembourg based Funds, you will:

• Act as Money Laundering Reporting Officer for the Funds, report any suspicious activities and transactions to and answer without delay any requests received from the Financial Intelligence Unit.
• Act as main contact for the Funds in the communication with authorities on financial crime matters – prepare and submit the Funds’ periodic financial crime regulatory reporting and regulatory submissions (e.g. Market Entry Forms), and answer ad hoc requests received from the regulator.
• Periodically review the Funds’ FC Compliance Policies to ensure they remain up to date and aligned with the Funds’ risk appetites.
• Assists the Funds’ Boards of Directors in defining the Risk Appetite of the Funds.
• Perform regular business-wide risk assessment of the Funds’ financial crime risks and present the conclusions to the Fund’s Board/RR, for approval.
• Provide SME advisory support for high-risk cases relating to the Funds’ customers.
• Conduct Compliance Assurance over the financial crime controls applied by the Schroders’ first line to the Funds, their initiators, investors, assets, and delegates. Where these controls are delegated to third parties, monitor and test the implementation of the delegation framework by the Schroders’ first line.
• Report the results of the Financial Crime Compliance/RC activity to the Funds’ Boards of Directors, in their capacity as Responsable du Respect des obligations (“RR”) of the Funds;
• Provide Financial Crime Compliance training to the Boards of the Funds.

The knowledge, experience and qualifications you bring

• Strong knowledge and experience of the interpretation of financial crime related regulations.
• Previous experience operating in financial crime advisory, oversight, assurance or monitoring role.
• Solid industry experience and understanding of financial crime related delegated activities risk in the Asset Management environment.
• Experience of engaging with regulators and other governmental bodies.
• Experience preparing Board, committee or senior management MI, including risk-based commentary, trends, threshold breaches, remediation status and issue ageing.
• Experience supporting regulatory reporting, due diligence questionnaires, policy/standards/guidance review, risk assessment or training delivery.
• Familiarity with financial crime-related controls, including enhanced due diligence, name screening and Transaction Monitoring processes.
• Strong, analytical and problem-solving skills with a strong level of attention to detail.
• Excellent interpersonal skills and the ability to build strong relationships with peers.
• Proven ability to interpret regulatory requirements and assess impact on business.
• Self-motivated with the ability to manage competing priorities and meet deadlines.
• Professional qualifications such as Association of Certified Anti-Money Laundering Specialists (ACAMS) and or International Compliance Association (ICA) or a willingness to study towards such a qualification is desirable.

We Recognise Potential, Whoever You Are

Our purpose is to deliver excellent investment performance to clients through active management. We believe diverse perspectives and an inclusive culture help us make better decisions and achieve better outcomes for our clients. That's why inclusion is a strategic priority for us, and we are an equal opportunities employer. You are welcome here, regardless of your age, disability, gender identity, religious beliefs, sexual orientation, socio-economic background, or any other protected characteristic.