Internal Control Officer

Roles and Responsibilities

1. Client Onboarding

• Ensure that KYC documents are complete correct and approved before an account is opened
• Ensure that all onboarding processes follow internal controls and regulatory requirements.
• Ensure that client data is properly stored in the right folders for audit and recordkeeping.

2. Client Direct Transactions (Subscription & Redemption)

• Ensure that all inflows and outflows are correctly identified recorded and processed.
• Ensure that supporting documents for subscriptions and redemptions are checked before approval.
• Ensure that units issued or cancelled are accurate and backed by proper documentation.
• Ensure that Bank details and client mandates match onboarding records before funds are released.

3. NonClient Directed Transactions (Coupon Distribution Repurchase)

• Ensure that coupon schedules and distribution schedules are correctly updated.
• Ensure that coupon schedules distribution schedules and repurchase approvals follow correct

procedures.

• Verify that client instructions (pay or reinvest) are followed accurately.
• Confirm that supporting documents are available and properly saved before postings are approved.
• Ensure that Trustees/SEC approvals are obtained before distributions or repurchases proceed.
• Ensure that registers are updated and reconciled once the non- client directed transactions have

been completed.

4. Valuation

• Ensure that daily prices transactions and corporate actions are correctly uploaded.
• Ensure that Bank balances reconcile with system balances daily.
• Ensure that valuation calculations (NAV/GAV) are accurate before EOD closure.
• Ensure that all valuation documents are properly saved for audit.

5. Investment Transactions

• Ensure that pretrade and pre- payment checks are done to avoid breaches.
• Confirm that trade approvals are obtained before execution.
• Confirm that trade documents (contract notes certificates allocation notices) are accurate and properly saved.
• Ensure that all trades are correctly posted and approved.
• Ensure daily reconciliation of custodian positions to prevent errors or fraud.

6. Reconciliation (Bank Custodian Counterparty Registrar)

• Ensure that all daily/weekly reconciliations are completed accurately.
• Ensure that all differences or discrepancies are investigated and resolved promptly.
• Ensure that reconciliation reports are reviewed approved and properly stored.
• Ensure that all reports meet audit and regulatory requirements.

7. Fee Accrual and Payment

• Ensure that daily fee accruals are correctly generated.
• Confirm that Finance validates the fees and all issues are resolved.
• Ensure that Management fees custodial fees and SEC fees are paid only after proper verification.
• Ensure that evidence of payment is stored and postings are approved.

8. Client Reporting

• Ensure that daily valuation and reconciliation are accurately completed to support monthly/quarterly reporting.
• Ensure that mutual fund statements and managed account reports are accurate before they are sent to unit holders.
• Ensure that supporting documents (valuations transactions reconciliations) are archived.

9. Internal Reporting

• Ensure that all internal reports (daily cash balances weekly portfolio report AUM report YTD non- discretionary report) are accurate and reviewed by the Head of Operations before being sent out.
• Ensure that all reports are saved correctly in the Operations Drive.

10. Regulatory Reporting

• Ensure that weekly SEC reports CTR/FTR PEP monthly/quarterly/halfyearly reports contain correct data.
• Ensure that reconciliations and valuations used for regulatory returns are complete and approved.
• Ensure that required approvals (Trustees Finance Compliance) are obtained before submission.

11. Data Management

• Ensure that all files are correctly named stored & backed up and only updated and approved documents sit in main folders.
• Ensure that sensitive data is protected and restricted to authorized staff.
• Ensure that records comply with 6year SEC retention rules.

12. Others (AGM & Repurchase)

• Ensure AGM documents reconciliations and reports are complete and accurate.
• Ensure all approvals for repurchase (Trustees SEC Board) are in place before execution.
• Ensure unit cancellations payments and reconciliations for repurchase are accurate.

Additional Roles & Responsibilities for an Internal Control Officer

• Develop and maintain a Risk & Control Matrix (RCM) across all operational processes.
• Identify and monitor key risk indicators (KRIs).
• Conduct periodic risk-based internal control assessments across departments.
• Identify control gaps and recommend corrective actions.
• Perform ongoing fraud risk assessments and control testing in highrisk processes (subscriptions redemptions vendor payments fee computation). Document findings and follow up to ensure corrective actions are implemented.
• Ensure segregation of duties.
• Ensure whistleblowing channels are working and confidential.
• Ensure regular access reviews for systems.
• Verify that staff who leave the company have their access immediately disabled.
• Work with IT to test disaster recovery & business continuity at least annually- (ensure backups for operations client records and corporate data are functional).
• Draft or update key policies like internal control policy/ charter and risk management policy. Recommend new policies when new risks or processes emerge.
• Conduct routine staff training on proper documentation standards and operational controls
• Ensure due diligence is carried out before engaging vendors.
• Monitor vendor SLAs to ensure obligations are met.
• Flag risks such as excessive dependence on a single vendor.
• Ensure timely updates and adherence to SEC rules
• Implement internal prechecks before any regulators review our records.
• Maintain an Incident Register (errors near misses fraud attempts) investigate the root causes and recommend preventive actions.
• Track financial losses and implement measures to reduce recurrence.
• Ensure every process has clear Standard Operating Procedures (SOPs).
• Maintain a central controls documentation repository.
• Coordinate with Internal Audit and External Auditors by ensuring all documents are uptodate and easily accessible and audit exceptions are closed.
• Monitor staff compliance with the code of conduct ethics policy gifts & entertainment Policy and conflict of interest policy
• Test new system features or upgrades to ensure controls are not weakened.
• Validate those automated calculations (e.g. fees valuations) are errorfree.
• Provide management with periodic reports showing emerging risk internal control weaknesses and trends in operational errors
• Help leadership make informed decisions based on risks and controls.

• Bachelors degree in Accounting Finance Economics or a related field.
• Minimum of 5 years experience in internal control risk management audit or operations within an asset management firm or financial institution.
• Strong knowledge of asset management operations
• Good understanding of SEC regulations and compliance requirements within the financial services industry.
• Strong analytical and problem-solving skills with high attention to detail.
• Proficiency in Microsoft Excel and relevant financial/portfolio management systems.
• Ability to identify control gaps and implement effective corrective actions.
• Strong understanding of risk management frameworks internal controls and audit processes.
• Excellent documentation reporting and communication skills.
• High level of integrity professionalism and confidentiality.
• Ability to work independently and collaboratively in a fast-paced environment.