Anti -Money Laundering Reporting Officer- Associate Director- Bermuda (Bermuda, BM, HM08)


  • Full Time

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Overall Description:

The Money Laundering Reporting Officer (“MLRO”)/ (“AMLCO”) will manage and control the firm’s compliance with money laundering and terrorism financing laws and regulations in Bahamas, Bermuda, British Virgin Islands (“BVI”) and Cayman Islands (collectively the “BBC”) and will be responsible for ensuring effective systems and controls are in place. The MLRO shall be a suitably qualified and experienced person at management level, to whom reports of suspicious activity (as it relates to money laundering or terrorism financing) will be made by Partners and employees of the firm.  He/she will be the final decision maker as to whether a Suspicious Activity Report (“SAR”) is filed with the appropriate regulatory agency for the respective jurisdiction and shall have access to all relevant material in order to make that decision.  The MLRO should be well versed in the different types of transactions that the firm handles and which may give rise to opportunities for money laundering. 


The MLRO/AMLCO serves as the primary liaison between the firm and regulatory agencies for matters involving money laundering or terrorism financing.  He/she also serves as a knowledge resource for matters involving money laundering or terrorism financing, is responsible for ensuring that an appropriate training program is in place, and maintains registers of reports received from members of the firm and SARs filed with, or inquiries received from, regulatory agencies.


Specific Tasks:


  • Keep up to date with legal, regulatory and industry practice
  • Maintain guidance in the Money Laundering and Financing Terrorism Policy Manual and in GTAC
  • Develop training WBLs and supplemental training documents as needed; keep up to date and make available to new-hires and existing personnel at appropriate opportunities; monitor and report on compliance with training requirements; communicate important developments as they occur
  • Provide general consultancy and helpdesk service for matters involving money laundering or terrorism financing
  • Receive suspicion reports from members of the firm; obtain further information as necessary to assess whether reportable; advise on client relationship implications including tipping off considerations; liaise with parent client teams in other EYG firms as appropriate; submit SARs to regulatory agencies; obtain confirmation, document and maintain case files
  • Maintain registers of suspicion reports received from members of the firm, SARs filed with regulatory agencies, and inquiries received from law enforcement or regulatory agencies
  • Monitor GTAC developments for integrity and adequacy of identification and monitoring procedures required by money laundering / terrorism financing regulations; contribute to question management system enhancements
  • Respond to GTAC queries regarding non-compliance with identification procedures and advise on achieving compliance
  • Monitor GTAC notifications of higher risk clients and engagements; review “not met client” cases for normality or follow up; review other cases for real risk and monitor progress after acceptance; maintain register of higher risk clients other than routine “not met client”
  • Monitor results of GTAC testing for implications for compliance with policies and procedures
  • Periodic risk review of the business to ascertain continuing appropriateness of procedures and guidance; identify any areas of higher risk and amend approach/procedures as necessary
  • Monitor retention policies for client files, GTAC records, etc. to maintain compliance with money laundering / terrorism financing laws and regulations
  • Compile statistics of suspicion reports and GTAC exceptions
  • Conduct an annual review assessing the operation and effectiveness of the systems and controls in relation to compliance with money laundering / terrorism financing laws and regulations, including testing of transactions with emphasis on high-risk areas; prepare annual MLRO report to include the results of the review and related issues
  • Act as primary point of contact on money laundering matters for law enforcement or regulatory agencies, other firms, etc., including managing regulatory inspections and other enquiries or requests for information
  • Coordinate and ensure timely filing of annual Proceeds of Crime Law (POCL) compliance confirmation with CIMA, due every January 31
  • Receive notification of sanctions update from the regulators and monitor compliance with various sanctions regimes, including ensure appropriate approvals are in place for sanctioned individuals or entities if applicable.
  • Regularly update the Board on all compliance manners, including coordinating Board approval for required Compliance matters


To Qualify for this role, you must have:


  • Bachelor’s degree or equivalent work experience
  • At least 10 years of experience within risk management, legal, anti-money laundering, compliance, audit or similar functions, preferably within the financial services sector
  • Effective communication skills, both written and oral on financial crime matters
  • Ability to liaise and communicate with the local regulator and law enforcement agencies/authorities as required, including providing management with an assessment of the results of such dialogue with those parties
  • Ability to be flexible and approachable, to work as part of a team, both within Bermuda and across jurisdictions


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