Client MLRO​/MLCO

Role Summary

The role holder will act as the appointed Money Laundering Compliance Officer (MLCO), Money Laundering Reporting Officer (MLRO), and Compliance Officer (CO) for licensed client entities serviced by the Client Compliance team. This position ensures that client entities meet all regulatory obligations under the GFSC framework, including AML/CFT/CPF requirements and compliance with applicable laws, rules, and codes of practice. The individual will provide assurance to Boards of client entities, oversee compliance monitoring, and act as the primary point of contact for regulatory and law enforcement matters relating to these prescribed roles.

I. Regulatory Responsibilities:

• Serve as the appointed MLCO, MLRO, and CO for designated client entities under GFSC laws and sector‑specific rules.
• Act as the primary contact point with the GFSC and FIU for all matters relating to AML/CFT and regulatory compliance for client entities.
• Ensure client entities maintain systems and controls that meet minimum licensing criteria, including compliance monitoring, risk assessments, and reporting structures.
• Oversee the timely filing of Suspicious Activity Reports (SARs) and ensure appropriate escalation procedures are in place.
• Maintain oversight of AML Business Risk Assessments (BRAs) and ensure these are reviewed and updated in line with regulatory expectations.
• Ensure compliance programmes for client entities are implemented and monitored effectively, including annual AML/CFT reviews and compliance monitoring programmes.

II. Monitoring & Investigation

• Oversee transaction and trigger event monitoring for client entities, ensuring alerts are investigated and resolved promptly.
• Lead or supervise investigations into suspicious activity and ensure accurate recordkeeping and reporting.
• Monitor typologies and trends to advise on enhancements to detection and monitoring processes for client entities.

III. Policy & Framework

• Ensure client compliance policies and procedures are maintained and updated to reflect regulatory changes and best practices.
• Implement appropriate controls, recordkeeping, and escalation processes for client entities.
• Provide input into client governance frameworks to ensure compliance obligations are embedded into decision‑making.

IV. Governance & Advisory

• Attend client Board meetings as required to present compliance and AML reports.
• Advise client Boards and senior management on regulatory risk exposure, licensing obligations, and compliance expectations.
• Provide regular, accurate, and risk‑based compliance reporting to client Boards and, where required, to Group functions.

V. Training & Culture

• Deliver targeted training to client entity Boards and staff on AML/CFT and regulatory compliance obligations.
• Promote a strong compliance and financial crime risk culture within client entities.

• Strong understanding of Guernsey regulatory regime and GFSC Handbook requirements.
• Advanced knowledge of AML, CFT, CPF, sanctions, and fraud prevention frameworks.
• Ability to interpret laws, regulatory notices, and implement changes effectively.
• Exceptional communication and interpersonal skills, with confidence to challenge and influence at Board level.
• High attention to detail and ability to manage competing priorities under pressure.

• Accountability:
  Takes ownership of prescribed roles and ensures timely resolution of compliance matters.
• Collaboration:
  
  Builds strong relationships with client Boards, internal teams, and regulators.
• Proactivity:
  Anticipates regulatory developments and acts with foresight.
• Clarity:
  Communicates complex compliance issues clearly and pragmatically.
• Integrity:
  Demonstrates ethical conduct and promotes compliance awareness.

• Professional compliance or legal qualification preferred (ICA Diploma, ACAMS or equivalent).
• Minimum 5+ years’ experience in compliance and AML within financial services, preferably in the funds industry in Guernsey.
• Proven experience acting as MLCO, MLRO, or CO for regulated entities.
• Strong working knowledge of Guernsey AML/CFT legislation and regulatory requirements.
• Experience preparing SARs, managing investigations, and liaising with regulators.