You will utilise your skills and experience to ensure that all requisite due diligence and tax transparency documentation and information is received by EFGFS, collated and recorded in line with AML / CFT and FATCA / CRS legislation as well as ensuring that appropriate regulatory monitoring and reporting is fulfilled in line with regulatory requirements. The portfolio of clients comprises inter alia venture capital, private equity, real estate and fund of PE funds, and structures include both open and closed ended funds and related entities.
The postholder will ensure that at all times clients receive a premier and proactive service, and that all due diligence activity is identified, prioritised and handled in an efficient, confidential and sensitive manner and that clients receive consistent high levels of service.
1. Be responsible for the attainment by EFGFS, the subsequent review and in principle approval of all due diligence (in line with AML and CFT legislation) and tax transparency documentation and data (in accordance with FATCA and CRS obligations) (collectively “CDD”) on funds and related structures serviced by EFGFS, together with their investors and shareholders;
2. CDD is initially collated on each new entity at the take-on / establishment of the structure, and on investors at the point each becomes an investor. In addition, on-going reviews are undertaken on a risk based periodicity;
3. Attain the necessary CDD documentation and data to meet regulatory and EFG Group requirements, liaising with the client service teams and / or the client / investor directly as appropriate. Review the CDD documentation and data and prepare the appropriate checklists, satisfying yourself that all requirements have been met (or highlighting any discrepancies) before passing to an EFGFS Director for review and approval: the file then requires final review and sign-off by the Director of Funds Governance;
4. Complete regular CDD reviews of client structures and investors. (The frequency of reviews of CDD is based upon the risk assessment of each entity / Where required contact clients and / or investors (in consultation with the client facing teams) for any replacement or additional documentation or information. Follow up all queries and discrepancies seeking guidance from the Director of Funds’ Governance as appropriate. Prepare appropriate checklists, satisfying yourself that all review requirements have been met (or highlighting any discrepancies) before passing to an EFGFS Director for review and approval: the file then requires final review and sign-off by the Director of Funds Governance;
5. Ensure all high risk investors / clients are correctly identified as such and that enhanced due diligence procedures are implemented and adhered to throughout the life of the relationship;
6. Assist in the preparation of regulatory reporting for client entities;
7. Assist in the ongoing monitoring of client entities preparing, for example, periodic reviews and compliance monitoring plans;
8. Assist with the investigation of AML and sanctions alerts, escalating where appropriate;
9. Keep up-to-date with changes in regulatory requirements liaising with the Funds Governance function to identify and implement any resulting changes to requirements and procedures. alerting the client facing team managers as appropriate;
10. Develop and maintain first class professional relationships with each client / investor, ensuring that all written, verbal and face-to-face communications are handled in an appropriate professional, efficient and timely manner;
11. Provide guidance and act as a point of referral for other members of the Fund Services department with regard to the attainment, review and completion of due diligence on investors and other connected parties, inclusive of obtaining tax transparency documentation. Liaise with the Funds’ Governance function to obtain the approval of CDD checklists;
12. Liaise with inter alia clients and investors to ensure the due diligence of client structures is conducted in accordance with EFG’s contractual, regulatory and legal obligations;
13. Assist client managers and directors, and guide other team members, during the establishment / take-on of new clients, including setting up bespoke procedures, populating records etc.;
14. Ensure procedures and checklists are updated as necessary;
15. Contribute to the attainment of the departmental generic objectives;
16. Ensure all activities and services are delivered in compliance with EFG policies and procedures. Where you believe it may be preferable to diversify from an established policy or procedure, raise this with a director and contribute to an assessment of whether such a diversification should be facilitated;
17. Ensure compliance with regulatory requirements including, where appropriate, Companies (Jersey) Law 1991, Financial Services (Jersey) Law 1998, Limited Partnership (Jersey) Law 1994, The Proceeds of Crime (Jersey) Law 1999, Collective Investment Funds (Jersey) Law 1988, Taxation (International Tax Compliance) (Jersey) Regulations 2014, the Income tax (Approved International Agreements (Implementation) (United Kingdom and United States of America) Regulations, 2014, The Taxation (Implementation) (International Tax Compliance) (Common Reporting Standard) (Jersey) Regulations 2015 and ensuring personal Continued Professional Development (CPD) requirements are met;
18. Undertake other “ad hoc” duties as required from time-to-time by the team manager.