The Compliance Officer will be responsible for the creation and implementation of a compliance and risk management framework for the Collective Investment Scheme and Management Company.
KEY RESPONSIBILITIES AND MAIN ACTIVITIES OF THIS ROLE:
- Compliance Policies and Procedures
- Maintain required policies and procedures including:
- Compliance Manual
- Complaints
- POPI
- FATCA
- TCF
- PAIA
- BCE Act / EE Act
- COIDA
- Governance (Gift Register, Director Declarations)
- Regulatory Reporting
- Responsible for production and/or oversight and submission of all regulatory reports timeously, including:
- FSCA Quarterly Compliance Reports
- FSCA Quarterly Stats (local and FCIS) and ASISA Quarterly Reporting
- SARB (K23, D427)
- Asset Allocation reporting to institutional clients
- Regulation 28 Reporting (including look through)
- Notice 910 Fit and Proper
- FICA
- Maintain the Risk Management and Compliance Programme to ensure full compliance with FICA and related anti-money laundering regulations
- Be appointed as the Money Laundering Compliance Officer
- Responsible for ongoing FICA training and control testing to ensure procedures are adhered to
- Portfolio Compliance Monitoring
- Monitor daily breach reports – in conjunction with Assets Operations team
- Investigate breaches reported and confirm validity
- Engage with fund managers to confirm validity and understand causes / mitigating circumstances
- Record breaches as appropriate and manage breaches to conclusion
- Monitor trustee breach reports and engage with trustees to ensure breaches are managed to the trustee’s satisfaction
- Manage the service level with the outsourced service provider and ensure the service is delivered according to the SLA.
- Ensure new portfolios are correctly setup and applicable rules are applied
Applicable Rules include:
- CISCA
- Regulation 28
- ASISA
- Fund Mandate
- Foreign CIS
- Ensure due diligence on underlying foreign scheme investments is done, and submitted to trustees for approval
- Ensure due diligence on underlying foreign scheme investments is reviewed annually
- Ensure all responsibilities in terms of foreign representation agreements are met
- Review FCIS prospectus changes as required and evaluate whether notification to FSCA is required
- Draft required applications to FSCA
- Advertising and Marketing
- Review procedures for advertising and marketing and update accordingly
- Submit or ensure submission of advertising and marketing material to FSCA
- Review application forms and update accordingly
- Ensure all material complies with BN92
- Includes Local CIS and Foreign CIS
- Investment manager due diligence
- Ensure due diligence with investment manager are reviewed quarterly, annually, adhoc for existing investors and full DD performed on new investment managers
- Applications to FSCA
- Draft applications for new portfolios and amendments to FSCA and manage to completion
- Draft supplemental deeds as required
- Company Secretarial
- Maintain the Combined Company register in accordance with regulation and best practice
- Ensure all provisions of the Companies Act are met
- Engage with the outsourced company secretary as required
- General
- Scanning of the regulatory environment and interpretation of impact of legislative changes
COMPETENCIES REQUIRED
- Working knowledge of and ability to interpret various relevant Acts and subordinate legislation:
- CISCA
- FICA
- An understanding of Exchange Control Regulations, Contract Law and Tax
- Display initiative, be proactive and take ownership of the role
- Sound decision making skills; commitment to appropriate actions
- Communicate effectively, written and verbal, in English
- Ability to work independently as well as within a team
- Systematic, organised working conventions, with attention to detail
- Ability to prioritise and plan appropriately
- Accountability for relevant tasks
CORE QUALIFICATIONS AND EXPERIENCE REQUIRED:
- You have experience as a compliance officer or similar role within the financial services industry
- You have working knowledge of financial services legislation, especially CISCA and FICA
- You have a certificate in Compliance Management, this would be an advantage but is not essential