Job Description

This role is responsible for Second line oversight, credible challenge of and guidance around the conduct risk framework, allegation management and registration regimes within the region inter alia. You will understand both the Enterprise Conduct Risk framework and EMEA relevant Conduct Risk related laws and regulations and how these apply to legal Entities and Individuals operating in EMEA.

In this role, you will be responsible for:

• Advising EMEA Wells Fargo First and Second Line in relation to Enterprise and EMEA relevant Conduct Risk requirements and how these apply within EMEA.
• Escalating (and resolving) any differences between Enterprise / Corporate Investment Banking / Commercial Banking / EMEA Regulatory conduct requirements.
• Setting out, agreeing and driving through the EMEA Compliance Program relevant to Conduct Risk (which must meet Enterprise and local standards) from a policy, procedure, rule capture, training, monitoring and reporting perspective.
• Reporting on Conduct Risk requirements to relevant forums as required / requested (from a Second Line perspective).
• Acting as key Second line SME, advisory point of contact for individual licensing relating matters (including Senior Manager and Certification (SMCR), MiFID II Knowledge and Competency requirements) and Allegation Management (including complaints and Whistleblowing).
• Overseeing First Line compliance with Conduct Risk Management requirements.
• As necessary managing Compliance employees aligned to Conduct risk.

Job Expectations:

1/. EMEA Compliance Program relating to Conduct Risk Management Conduct Oversight

• Work across Enterprise, CIB and EMEA Compliance and Independent Risk Management teams to stay current with Wells Fargo requirements for Conduct Risk Management.
• Create, drive through and maintain a documented Compliance Program relating to the Second Line Conduct Risk Framework for the EMEA Region. The Program must meet:
  • Enterprise Conduct Risk / Risk Management Framework requirements (as applicable).
  • EMEA Conduct Risk related regulations and best practice.
  • Enterprise Compliance Program requirements for the Second Line.
• Maintain and drive through an associated RACI (document outlining expected roles and responsibility) across First line and Second line teams relating to the EMEA Conduct Risk Program.
• From a Compliance perspective, this must cover the Senior Manager's key role in relation to (inter alia):
  • Regulatory Change relating to conduct risk matters (risk identification and oversight of conduct risk related implementation projects).
  • Breach Reporting (contributions and oversight).
  • Allegation Management including Complaints and Whistleblowing.
  • Policy and Procedure development.
  • Learning and Awareness requirements.
  • Monitoring and Oversight.
  • Governance Reporting (to forums, committees etc. internally within Enterprise / CIB and EMEA Compliance) etc.

2/. Advisory Services and Oversight in relation to Conduct Risk matters

• Advise First and Second Line in relation to Enterprise and EMEA relevant Conduct Risk requirements and how these apply within EMEA.
• Escalate (and resolve) any differences between Enterprise / Corporate Investment Banking / Commercial Banking / EMEA Regulatory conduct requirements.
• Act as an advocate and Leader for Conduct Initiatives. This will include advice on (in conjunction with other Compliance SMEs as appropriate):
  • Market Conduct and Supervision - including Programs relating to Insider Threat Risks, Sales Practices.
  • Ethics Risk Programs including those relating to Conflicts of Interest, Gifts and Entertainment, Travel and Expenses, Political Contributions / Activities.
  • Front Line Supervisory Frameworks.
  • Conduct and Customer Resolutions (including complaints, allegations, whistleblowing).
  • New Business Initiatives (conduct risk implications relating to new initiatives / products).
  • First Line Risk and Control Self Assessments (providing guidance on major conduct risk related requirements and how these are applicable to the First Lines of business operating in EMEA.)
  • Regulatory Change Projects - providing advice in relation to conduct risk related impacts etc.
  • Integration of Conduct Risk within existing Compliance structures including risk assessment processes, monitoring and reporting.
  • First Line produced Risk Scorecards, Business Risk Strategies and EMEA and Legal Entity Statements of Risk Appetite.
  • Second Line produced Risk Assessments (including Enterprise, CIB, EMEA related compliance risk assessments, from a conduct risk perspective.
• Support Compliance's oversight responsibilities in respect of the EMEA Whistleblowing framework, including management information and reporting to the Head of Compliance and relevant Compliance Leaders, senior management and legal entity boards and committees.
• Act as point of contact for policies and procedures (drafting as necessary) which fall within the team's remit (including conduct and whistleblowing policies and those relating to individual licensing frameworks such as SMCR).
• Provide support to the EMEA Conduct & Fitness Panel and relevant forums as directed.
• Oversee the creation of First Line Action plans to address Process and Control Gaps as directed. Determine the potential impacts of Process and Control gaps e.g. in relation to regulatory and or audit risks which will need to be escalated appropriately.

3/ Advisory Services and Oversight in relation to Regulatory Registrations

• Develop a program related to oversight of registration regimes from a second line perspective to ensure compliance with all applicable Compliance rules, regulations, internal policies and procedures.
• Support the delivery of compliance related tasks related to SMCR, and other conduct related regulatory regimes as required.
• Support the development and implementation of Second-line oversight responsibilities for Senior Managers and Certification Regime and other conduct related related regimes.
• This may include training and awareness activities, attestations, potential monitoring relating to First line activity etc. as required.

4/. Leadership

• Contribute toward a strong risk culture that identifies and provides oversight and escalation of existing and emerging compliance issues across business groups, legal entities, geographies, and jurisdictions in the EMEA region, and ensure that escalated compliance issues related to the EMEA region receive appropriate senior management attention.
• Create a culture of excellence by proactively attracting, retaining and developing a team (where allocated) of talented and diverse compliance professionals to support the execution of the Enterprise Compliance Program across EMEA.
• Prepare and coordinate reporting for relevant Compliance management meetings, CIB Compliance periodic audit related requests, business Committees and Working Groups, and present at relevant meetings where required.
• Report status updates on an ongoing basis for Compliance management in relation to progress against activities under remit.
• Develop KRIs and KPIs (Key Risk Indicators and Key Performance Indicators) as appropriate and demonstrate trending as required.
• Assist in the management of regulatory examinations and enquiries and represent the company on conduct related issues as required / requested.
• Work with the Compliance Management team in addressing any issues arising from regulatory and or other examinations (including internal audit, testing and validations etc.).
• Concerning the Conduct Risk function / Conduct Risk management in EMEA.
• Maintain good audit discipline to include regularly updating procedures, appropriate storage of documentation and supporting with requests relating to Issue Management, Testing and Validation.
• Support with other relevant cross-team / department tasks as directed.

Required Knowledge, Skills, and Abilities

• Educated to degree level with a background in a compliance team at top tier wholesale bank and/or consultancy firms.
• Proven background / exposure to risk and control frameworks / projects.
• Extensive experience of enterprise Compliance programs, including conduct risk identification and assessment processes, Compliance issue management, new product/business review, complaint handling, Compliance monitoring and reporting, Compliance training.
• Excellent knowledge of EMEA regulatory environment and how conduct risk and regulatory registrations apply to wholesale banking lines of business is essential.
• Proven experience of oversight of conduct risk frameworks.
• Project Management - excellent project management skills, strong stakeholder management skills and ability to think strategically, act swiftly and deliver results transparently and timely are essential.
• Candidate must have expert analytical skills with experience in collecting, analyzing, and synthesizing information on various subjects. Demonstrable experience of leading teams.
• IT literate - Familiarity will be required with the firm's governance, risk and control database with training provided, hence strong understanding of governance risk and control databases is advantageous.
• Literacy to include Microsoft products and ability to understand use of technology for improving the regulatory control environment.
• Flexibility / Initiative - ability to manage multiple requests for information and handle confidential and sensitive information in a professional manner in a fast paced deadline driven environment.
• Strong analytical, critical thinking and problem-solving skills, coupled with an ability to translate ambiguous ideas/issues into well-defined plans/solutions with a track-record for delivering results.