The individual performing this role is subject to the following:
Annual completion of relevant:
Group Compliance Training Modules
Global Corporate Compliance Training
Local Compliance Training Modules
Ongoing assessment of Fitness and Propriety (F&P) of which the core categories are:
Honesty Integrity Reputation
Competence and Capability
Financial Soundness
Responsibilities
The positionhas the following responsibilities:
PRINCIPAL ACCOUNTABILITIES AS COMPLIANCE OFFICER
REGULATORY RELATIONSHIP
Act as main point of contact with the local Regulators and establish effective systems and controls to maintain and enhance the relationship. Keep a formal record of all regulatory correspondence sent and received. Escalate key matters arising to Group Compliance as necessary.
HORIZON SCANNING
Implement and maintain a framework for monitoring all relevant local legal and regulatory changes assess the impact on local regulatory compliance and advise the affected functions within the location and the wider FCE Group accordingly.
COMPLIANCE RISK REGISTER (CRR)
Identify key Compliance risks facing the location and be accountable for ongoing development and maintenance of the locations Compliance Risk monitor and evaluate the adequacy and effectiveness of the control framework in place to mitigate risks noted in the CRR.
COMPLIANCE MONITORING
Develop and take ownership of a Compliance Monitoring Programme for the Intermediary ensure that regular compliance monitoring takes place. Update the Compliance Monitoring plan at least annually and as required.
POLICIES & PROCEDURES
Develop and maintain all compliance related Policy Letters Procedures and written standards.
TRAINING
Develop implement and maintain an ongoing compliance training framework that aligns with regulatory expectations and peers. Leverage Group training materials and platforms where possible.
BREACHES
Analyse monitor and report any compliance breaches and support the development and implementation of suitable measures to prevent recurrence.
GOVERNANCE
Develop and participate in (including chairing as appropriate) suitable compliance and risk committees including mechanisms for escalating matters to senior management Group compliance and the Regulators as necessary.
GOVERNANCE
Provide a regular status updates (annually as a minimum) to the location directors and senior managers on all compliance matters
POLICIES & PROCEDURES
Develop and maintain processes and procedures to ensure effective and efficient compliance with applicable regulations including local regulations antimoney laundering regulations and any other relevant regulatory requirements. Ensuring alignment with other European and UK offices as appropriate.
STRATEGY
Support the development and implementation of strategic initiatives and priorities to ensure compliance advice is considered.
UNUSUAL EVENTS
Implement a framework to track and report the status of Incidents and Whistleblowing matters from the location to relevant Committee and assist FCEs Whistleblowing Champion with onward reporting to external bodies and the Board of Directors as appropriate
BUSINESS CONTINUITY
Responsible for implementing and overseeing a suitable Business Continuity Incident Management Plan for the compliance function.
DATA PROTECTION
Local support and point of contact of the Ford/Ford Credit European Data Protection Officer
PRINCIPAL ACCOUNTABILITIES AS AML OFFICER
REGULATORY RELATIONSHIP
Maintaining an appropriate relationship with all relevant AML & Financial Crime regulatory bodies.
REGULATORY RETURNS
Where necessary develop and submit AML related regulatory and supervisory returns to the relevant local Regulators.
GOVERNANCE & REPORTING
Provide a regular status update (annually as a minimum) to the location board of directors and senior managers on all AML and Financial Crime related matters including Sanctions and PEP Screening Suspicious Activity Reporting and Fraud. Escalate key matters arising to Group Compliance as necessary.
RISK ASSESSMENT
Design and implement a dedicated AML and Financial Crime Risk Assessment document for the location. Ensure this remains uptodate and accurate. Obtain annual approval from the location board of directors and senior managers. Escalate key matters arising to Group Compliance as necessary.
TRANSATION MONITORING & SARs
Maintain an effective reporting process for suspicious transaction reports.
PEPs & SANCTIONS
Ensure appropriate screening against Sanctions and Politically Exposed Persons (PEP) lists; act in the event of a response to potential matches ensuring compliance with the regulations.
PEPS
Review and approve initial PEPs
Review and approve existing PEPs
Maintain detailed and accurate MI of all PEPs
Escalate adverse media and high risk PEPs to Group Compliance
SARs
Oversee transaction monitoring alerts
Review and approve SARs
Escalate SARs to board and senior management
Report SARs to location financial intelligence unit and manage any ongoing dialogue with them on referrals
Maintain detailed and accurate MI of all SARs received and action
RPS User Admin & Accuracy Oversight:
Approve/Remove Users into the location RPS hierarchy
Daily/Weekly/Monthly RPS Reconciliation reporting review challenge and analysis
Manage Changes & updates to listings test new names added for completeness
Analyse name discrepancies and queries re: accuracy
UAT and OAT of changes to RPS
AML related Banking Questionnaires
Complete all AML banking questionnaires on request
Ensure Wolfsberg on file for all banking partners revisit and update annually as a minimum
TRAINING
Responsibility for training awareness and instructing employees on methods of money laundering terrorist financing and how to record and report suspicions.
CULTURE
Serve as a contact person in all matters AML and Terrorist Financing for colleagues.
INTERNAL AUDIT
Attend meetings with Internal Audit support with information requests & questions support remedial actions required to close comments
DATA PROTECTION / PRIVACY
Liaise with Ford/Ford Credit European Data Protection Officer and implement local initiatives to comply with data protection and privacy Spanish and EU laws
Qualifications
Education and Experience:
Qualifications:
Degree educated with a minimum of 5 10 years of experience in a senior compliance role within the financial services industry. Proven experience managing relationships with regulatory authorities.
Regulatory Expertise:
Deep understanding of Spanish and European Union financial regulations. Knowledge of relevant industry best practices Spanish financed sales in installments and financial lease regulations and Spanish and European Union data protection laws is highly desirable.
Analytical and ProblemSolving Skills:
Exceptional analytical skills with the ability to identify assess and mitigate compliance risks effectively. Strong problemsolving skills and a proactive approach to identifying and resolving issues.
Communication and Leadership Skills:
Excellent written and verbal communication skills in Spanish and English. Strong leadership skills with the ability to influence and motivate teams across different departments.
Desired Characteristics:
Experience working within a global organization.
Understanding of the automotive finance industry.
Ability to simplify complex information and communicate it effectively to diverse audiences.
Proven ability to build consensus and collaborate effectively with various stakeholders.
A proactive resultsoriented approach with a strong commitment to ethical business practices.
Ford is committed to diversity and equality of opportunity for all and is opposed to any form of less favourable treatment or harassment on the grounds of gender marital
status civil partnership status parental status race ethnic origin colour nationality national origin disability sexual orientation religion/belief gender reassignment and
gender identity age and those with caring responsibilities.
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