Marisa Jude

• As a second line of defence role, responsible for oversight of compliance with UK rules and regulations relating to money laundering, terrorist financing, sanctions, bribery and corruption, anti-proliferation financing and tax evasion for Rathbones Asset Management (RAM) and to deputise and support the MLRO of all other UK regulated entities of Rathbones Group Plc (‘Group’).
• Carry out responsibilities of the ‘nominated officer’ under the UK Money Laundering Regulations for the RAM entity and deputise in the absence of the MLRO for other Group entities.
• Responsible for ensuring that RAM has robust and appropriate systems and controls and understanding risks to which it is exposed to, whilst supporting the MLRO of other Group entities to ensure the same.
• Maintain up to date and relevant financial crime policies and procedures and the Business Wide Risk Assessment.
• Review and approval of PEPs and other high risk clients.
• Take reasonable steps to ensure that RAM and other Group entities, obtain and make proper use of any government, regulatory or FATF findings in line with Financial Crime Guide (FCG) in the FCA Handbook.
• Own, develop and deliver awareness and training solutions as appropriate for UK employees.
• Responsible for providing regular reports to the RAM board and executive committee, as well as to the Group Board and Executive Committee, including the annual MLRO report, on the operation and effectiveness of anti-money laundering systems and controls.
• Own and respond promptly to any reasonable request for information by UK regulators or law enforcement.
• Responsible for accurate and timely submissions of Regulatory Reports, including the FCA Financial Crime Return.
• Advise and support the business on Financial Crime related matters, ensuring a balance between regulatory compliance and good customer outcomes.
• Supervise, mentor and provide guidance to the Financial Crime Team.

Deputising for the MLRO as part of the Financial Crime Compliance (2LOD) Team, duties include:

• Leading and acting as FCC SME for any regulatory or industry led changes, including summarising potential change and impacts; liaising with both internal and external stakeholders
• Responding to industry consultations where required
• Leading and acting as FCC SME for on any financial crime related projects, ensuring any relevant risks and considerations are raised and addressed
• Attending regulatory, technical & external compliance meetings and forums, for example TISA, IA, TA Forum
• Providing FCC support on legal, technical and regulatory matters to the Compliance team and SS&C business areas
• Respond to any queries from Management Companies which may relate to a regulatory or procedural matter
• Produce the Annual MLRO Report for agreement by the MLRO
• Responsible for content and design of regulatory financial crime training for all staff
• Reviewing of procedures to ensure they are updated to reflect regulatory/legal changes
• Updating the risk assessment annually, or as and when required
• Organising and minute-taking for the internal monthly FCC Committee meeting
• Organising and leading of ad hoc Management Company meetings, where the topic is financial crime related (such as Focus Group Meetings relating to regulatory change, Experian Upgrade, Corporate Clients)
• Organising, presenting and minute-taking of quarterly FCC Forum for Management Companies
• Raising and seeing through to conclusion any changes or initiatives that may be raised at the FCC Forum
• Liaise with the business regarding change resulting from any financial crime initiatives
• Review and update FCC sections of the Corporate Governance Manual, Compliance Manual and Financial Crime related policies
• Attending Management Company Compliance Review meetings in relation to FCC
• Oversee fraud trends that may be present across Management Companies and suggest and where required see through any required change
• NB FCC scope pertains to AML, Fraud, ABC, Tax Evasion and Whistleblowing.

• Responsibility of preparing and carrying out the Compliance Monitoring Programme within prescribed timescales
• Monitoring of regulated activities, making recommendations where appropriate and seeing them through to implementation with support of the business
• Checking of all account openings to ensure they are in line with internal and regulatory CDD/KYC requirements
• Updating of all policies and procedures in line with regulatory developments and guidelines, including client on-boarding
• Acting as the first point of contact for queries
• Daily clearance of potential sanction list matches, escalating to the MLRO where appropriate
• Analysing internal SARs and report to SOCA if necessary
• Providing summaries of FSA and other relevant papers to Senior Management and making recommendations where necessary
• Providing training to staff
• Keeping senior management up to date with regulatory developments via board reports and the annual MLRO report
• Dealing with any Production or Freezing Orders
• Ensuring the Compliance Intranet site remains up to date and includes relevant information that is of use by the wider business
• Initial review of any new PEPs that may wish to become a client
• Provide MI for the board report relating, including failure rates for new account openings and pass rates for online AML test.

Working as part of a small compliance team overseeing Banking and Investment Management duties included:

• Regular monitoring of all regulated activities such as execution only, discretionary management, custody, large holdings and material interests, AML/KYC and RMCs
• Updating of AML policy and procedures
• Assisting the MLRO with AML requirements including database checks, reporting of suspicious activities to SOCA, monitoring of customer accounts and liaising with external authorities
• Daily clearance of sanction list matches, and referral to authorities where required
• Maintenance of all relevant Compliance logs.

• Referring reported breaches within 24 hours to the relevant Fund Manager
• Making recommendations to ensure processes and procedures are up-to-date

• Supporting the Financial Crime Prevention team to review and where necessary, refer Internal Suspicions Activity Reports to various Fund Managers.