Compliance Monitoring Manager

The Compliance Monitoring manager reports to the Group Head of Compliance Operations.

Ebury’s Compliance Monitoring Programme (CMP) is part of Ebury’s internal control
framework. Its purpose is to ensure that all items relating to regulatory, central and business
compliance are undertaken in accordance with the regulatory or business requirements as
these are either defined by applicable laws and regulations or the business internal policies
and expectations. The CMP also ensures that the business activity remains within the
business risk appetite.

The objectives of the CMP are:

● Achieve Regulatory Compliance: Everything that will be monitored will aim to help
achieve compliance with our regulatory obligations.
● Compliance with our Policies and Procedures: Our monitoring will ensure that our
policies and procedures remain compliant on an ongoing basis.
● Manage Risk: Through ongoing monitoring, we can achieve reduction of risk
(including residual risk).
● Management Information: Information collection and analysis of data on our ongoing
compliance and errors/mistakes/ cases of non-compliance.
● Detection: Helps identify compliance issues before they escalate into significant
problems.
● Assurance: Provide assurance to the business that the risks identified are properly
monitored and mitigated/managed where required.
● Operation: Ensure that the firm operates within the risk appetite as this has been set
by the senior management.

This is a Group Level function. Every authorised entity within the Ebury Group has its own
regulatory requirements to perform monitoring which is set at the time of authorisation as
part of the regulatory approval to operate. Ebury takes a group-wide risk approach in its
application of monitoring with a centralised monitoring team, setting the items which will fall
under its monitoring purview and providing the regional and/or local Compliance
Officers/MLROs with the ability to request specific items to be monitored. The Compliance
Monitoring Manager will need to liaise with regional compliance officers and the Group
Regulatory Compliance Advisory function to ensure that the central CMP addresses any
relevant local factors that cannot be covered locally.

The scope of the CMP includes, but is not limited to:

● Breaches, Conflicts, Conduct, Complaints;
● Call monitoring;
● Client trade monitoring (MifID or local equivalent);
● Best Execution;
● Mis-selling;
● Client treatment;
● Safeguarding;
● Staff training;
● Limited monitoring of Ebury partners and agents.

Roles and responsibilities:

● Ongoing development of the CMP, including periodic horizon scanning and risk
assessments to ensure that the scope remains complete and accurate.
● Ownership of maintenance and development of the Compliance Monitoring
framework including specifications, sample sizes, frequencies, testing plans and
scorecards for each element of the CMP.
● Execution of the CMP to assess compliance with all applicable regulations and
internal standards
● Planning and conducting risk-based ad hoc deep dive or thematic reviews as
directed by Senior Management or Governance forums.
● Line management and day to day management of 1 Compliance Monitoring Senior
Analyst.
● Analysis of findings and tracking of actions required on material risks through to
closure.
● Main point of contact for all business requests for the establishment of monitoring
items.
● Prepare management information on monitoring activity for relevant committees.

Key skills and attributes:

● Experience of regulatory compliance and/or compliance monitoring or assurance
working in an FCA regulated firm, ideally within a payments or fintech environment.
● Experience of designing monitoring plans and managing and continually improving
compliance monitoring methodology
● Excellent organisational and problem solving skills.
● Confident in communicating compliance matters to a range of audiences
● Strong stakeholder management skills
● Regulatory knowledge of MiFID, CASS, COBS, FCA principles, financial promotions,
best execution, client classification.

#LI-SM1

#LI-onsite