Primary role as CF10a of CBAM with overall responsibility for operational oversight of and compliance with CASS across the Division.
To manage the implementation of Projects within Operations Teams resulting from Regulatory Change and ensure CASS is considered in any other Business Change.
KEY RESPONSIBILITIES General
Overseeing the operational effectiveness of systems and controls that are designed to achieve compliance with CASS.
Reporting to the firm's governing bodies in respect of CASS oversight through quarterly updates to the Risk and Compliance Committee and attendance and participation at meetings as required.
Chairing the CASS Committee. Completion and submission to the FCA of the Client Money and Asset Return (CMAR).
Completion of the firms' prudent segregation calculation, reporting on same to CASS Committee and RCC and implementation of any necessary adjustments to segregated balances.
Completion of annual review of banks and custodians in accordance with CASS rules, the diversification of client money balances and reporting on same to CASS Committee and RCC.
Liaison with external auditors in respect of the completion of the annual CASS Audit report.
Liaison with Group Internal Audit and Compliance in respect of all CASS related audits and monitoring.
Maintenance of the CASS Mapping Framework, CASS Risk Assessment, CASS Control matrix and all related policies and documentation.
Maintenance of the CASS RP and reporting to RCC on compliance with the CASS RP maintenance requirements.
Providing leadership and direction to the CASS & Reconciliations team on a day to day basis.
Provide direct management of the Manager of the CASS and Reconciliations Team, ensuring coordinated development and training plans are in place for all members of the team. Ensure proper succession plans are in place. Undertake appropriate coaching and performance measurement.
Ensuring day to day operational procedures relevant for CASS compliance are efficient, comprehensive, fit for purpose, adequately documented, communicated and adhered to.
Effectively managing operating risk through a robust set of controls and escalation procedures, working with all parties in response to operating events to strengthen controls.
Ensuring procedures are compliant with all relevant regulatory and legal considerations and the team is properly trained to carry out such responsibilities. Identification and oversight of projects to improve CASS Compliance, our service capabilities and operational effectiveness.
Liaison with business heads across the Division to implement any necessary changes to processes in relation to CASS.
Where process enhancements or new processes are introduced as a result of business change, ensure that CASS is considered and appropriate controls are implemented.
Implementation of CASS training Oversight of third party and supplier relationships on behalf of Operations where CASS
Compliance is required, including membership and participation within the Third Party Oversight Committee (TPOC).
Regulatory Responsibilities (Compliance/T&C)
In this role, you will be assigned responsibilities and provide services to Close Asset Management Limited, Close Investments Limited and Close Asset Management (UK) Limited.
Understand, follow and demonstrate compliance with all relevant internal and external rules, regulations and procedures that apply to the conduct of the business in which you are involved. Specifically this includes following principles and rules of the Financial Conduct Authority (FCA) and the internal requirements set out in the Compliance Manual, local and Group Compliance and Risk policies.
Follow the FCA's Treating Customers Fairly (TCF) principle by adhering to all relevant internal TCF policies, considering how TCF affects your role and act in a manner which helps to ensure fair outcomes for clients.
To adhere to the relevant Asset Management Division policies, including those on conflicts of interest, gifts and entertainment at all times.
To follow the Group and local rules on personal account dealing as set out in the Group Personal Dealing Rules and supplemented by specific additional local requirements set out in the relevant Compliance Manual. e To fully comply with the relevant Anti-Money Laundering regulations, specifically relating to the verification of clients and report promptly any knowledge or suspicion of money laundering activities to the relevant MLRO.
As an approved person you must accept responsibility and demonstrate an understanding for the regulatory aspects and framework of the FCA controlled function that you perform, and ensure you meet and abide by the rules of the FCA's fit and proper test, and comply with the