Compliance Officer & MLRO
A job that can cover regulations at funds and company level
Compliance Officer and MLRO roles vary from one company to another. The compliance department is there to protect the company, its employees, funds, and clients, and to make sure they all respect new and old regulations.
While in some companies a Compliance Officer will have 3 years of experience, in some others it might be someone with 8-10 years of experience. Titles can be misleading in Luxembourg! MLRO (Money Laundering Reporting Officers) usually have 5+ strong years of experience within AML.
The compliance department is there to protect the company, its employees, funds, and clients, and to make sure they all respect new and old regulations. Compliance Officers are relatively senior oversight roles, where they are responsible for analysing the situation, any potential risks, and suggesting solutions (e.g. how to implement new procedures/processes to comply with the law). Our clients usually have between 1-3 people focusing on AML/KYC, and 1-3 on regulatory compliance, depending on their size and structure.
Hence, we can find Compliance Officers focusing on the regulations that will impact the Management Company in itself, and some working at funds level, closely evaluating investors, distribution, products, and even various geographies that these elements are based in. Compliance Officers may cover both the Manco compliance, as well as the fund compliance.
In general, compliance officers will work closely with Senior Management, but there is always a degree of separation
That way they can step back a little in order to advise them well regarding compliance topics, such as new regulations, raising any flags, training staff, and all that is required to ensure the effective implementation of Compliance Monitoring Programmes. They will oversee legal and regulatory watch, prepare compliance reports for boards and relevant authorities, and drive the compliance awareness culture within the company.
These roles are in high demand
Thanks to a range of new circulars and regulations aimed at protecting fund investors and the financial system as a whole.
The financial regulatory environment is becoming highly complex and requires well-informed employees to avoid issues, and in the worst cases, sanctions.
In the last five to seven years, since the introduction of the new Management Company regulations, AIFMD, and BEPS, the profile of companies has changed a lot in the Compliance space. Companies are obliged to have several people in compliance/risk with separated responsibilities, meaning the person producing compliance or risk cannot be the one reviewing it anymore. Companies have no other choice but to hire new employees to comply with the laws.
At the more senior levels, employees will have to be CSSF approved. They will look at the employee’s experience to evaluate if yes or no he/she is up for the job. Because most regulations/circulars are made for and by Luxembourg, most of our clients will only consider candidates with working experience in Luxembourg. Sometimes, they can be flexible when recruiting an MLRO.