To ensure that BNP Paribas Asset Management Australia (BNPP AMAU) is in full compliance with applicable local regulatory requirements as well as BNPP Group Compliance standards. This includes providing proactive compliance advice to the business and the roll-out of Group Compliance policies and standards.
Perform compliance and risk monitoring and testing of all activities of BNPP AMAU business and monitor adherence to investment guidelines, local regulatory requirements and global group standards, as directed.
Monitoring and participating in the co-ordination of Operational Risk and Control activities for BNPP AMAU.
Assist in co-ordinating Business Continuity-related activities for BNPP AMAU.
- To represent the Compliance function in BNPP AMAU’s Management Committee and other business and operational committees. To ensure that approriate Compliance oversight arrangements are in place.
- To act as an escalation and decision making point (within scope of expertise) for material Compliance topics impacting BNPP AMAU. To report all material Compliance issues, progress and resolution as needed.
- To monitor the quality and completeness of implementation of the Group Compliance framework in BNPP AMAU, liaising where necessary with the relevent Compliance domain head and the Head APAC & LATAM Compliance. Maintain an annual Compliance Action Plan defining clearly the Control plans and coverage for all Compliance domains - Financial Security, Market integrity, Professional Ethics and Client Interest Protection. To actively monitor the status of Compliance controls, gaps and actions required for closure via the CCRM tool, ensuring the role of Compliance as a second level controller.
- Actively ensure new regulatory trends and requirements are identified and addressed. Perform ongoing assessment of company acitvities to ensure compliance with local regulatory requirements.
- To ensure all staff are aware and appropriately trained on the Compliance expectations of the local regulator and the BNP Paribas group. To help develop a strong compliance culture within the entity, with a focus on Professional Ethics and Client Interest Protection.
- To manage and maintain the relationship with ASIC and other regulators, representing the function in relevant industry forums.
- Reviewing marketing, promotional and communication materials and tools/collateral from a regulatory compliance perspective to mitigate risk of miss-selling and reputational risk and regulatory breaches.
- Daily exceptions review of SUN Fircosoft alerts.
- Recording and maintaining registers: Incident Register; Personal Account Dealing Register; Outside Business Interests Register, Regulator Register and Conflict of Interests Register; Complaints and complaints register as needed.
- Weekly incident status emails to service providers.
- Providing training on compliance matters ensuring a compliance culture across BNPP AMAU, including new starter training.
- Assist with due diligence requests for information from Responsible Entity (Annual Investment Manager Due Diligence) or for RFPs and other general requests.
- Providing compliance input, due diligence and recommendations to BNPP AMAU business projects and regular/ongoing BAU activities such as: third party agreements; new product initiatives, new and updated offer documents/product disclosure statements.
- Providing compliance assistance to BNPP AMAU in relation to client complaints generally.
- Reviewing Australian regulatory developments relevant to BNPP AMAU (eg: ASIC, AFSL, Austrac, AFCA) and its compliance and control framework and reputation, and assisting the business as needed with appropriate responses such as: communication to the business of impacts; updating or implementing compliance policies and processes in response to such developments; including licensing, substantial shareholding (if required) and BNPP AMAU Trust-related obligations (eg, compliance plans).
- Act as a compliance co-ordination point for any internal audits or inspection generale and manage recommendations;
- Assist with responding to internal and external audit queries and requests for information;
- Follow up and ensure implementation of audit recommendations and that open items are closed within agreed deadlines.
(b) Service provider monitoring
- Liaise with investment managers on investment compliance certifications, licensing compliance and violations/breaches.
- Liaise with service providers including Custodian & Administrators and Responsible Entities on Trust investment compliance and risk-related issues.
- Conduct BNPP AMAU’s due diligence and compliance oversight program of key service providers (including any authorised representatives), including oversight of the adequacy of ongoing reviews.
- Monitor breaches and errors and ensure proper reporting, escalation and corrective measures are taken.
(c) Regulatory compliance monitoring
- Perform quarterly or other regular compliance testing (eg: GCP/KPRI).
- Perform quarterly or other regular register testing, as required (eg: PAD/Gifts).
- Preparation of annual compliance risk assessments (AGORA/Compass/GRAM).
- Preparation of annual AML/CTF risk assessment and assist generally with related AML/CTF compliance matters for BNPP AMAU.
- Assist in implementing compliance monitoring programs, policies and compliance projects including AFSL fit and proper and responsible manager monitoring.
- Maintain up-to-date documentation of compliance policies and procedures.
- Co-ordinating and submitting AFCA annual assessment and ASIC annual levies assessment and other regulatory assessments as required.
- Arrange for various regular and ad hoc ASIC and other regulators’ filings and updates as may be required, including lodgement of filings (eg: LSE/LEI registration, US IRS details for FATCA purposes; various ASIC and AFSL, responsible manager, and other notifications and filings).
- Assist in organising and co-ordinating the BNPP AMAU Internal Compliance and Control Committee, including compliance and risk reporting to it, and assistance with compliance reporting to the BNPP AMAU Board.
- Preparation of Committee papers (Internal and Territory Committees)
- Preparation of monthly/quarterly/annual Compliance certifications to clients, if required.
- Assist with compliance related queries from the Group, and local APAC compliance projects, as needed.
(e) Risk review and testing
- Conduct and manage Operational Risk and Control monitoring and testing.
- Manage BNPP AMAU BCP requirements and testing.
- Manage BNPP AMAU’s Risk Appetite Statement documentation obligations (ASIC RG 259 requirement).
- Other administrative tasks, as directed.
- Adhere to policies and procedures contained in the term of employment, including BNP Paribas’ General Code of Conduct and its addendum on anti-corruption.
Monitoring and participating in co-ordination of Operational Risk and Control activities for BNP Paribas Asset Management Australia.
- Co-ordinating the annual risk mapping exercise
- Perform half-yearly Key Surveillance Points (“KSP”) testing.
Assist in co-ordinating Business Continuity-related activities for BNP Paribas Asset Management Australia.
- Co-ordinating the annual Business Impact Analysis review.
- Co-ordinating the completion of the annual Beneficiary Questionnaire.
- Liaising with Country BCP in relation to BCP testing requirements for BNP Paribas Asset Management Australia.