EMEA Investments Chief Compliance Officer (CCO)

Position:  EMEA Investments Chief Compliance Officer (CCO)

Job Location: London

Corporate Ethics and Compliance

Situated within Global Risk, Corporate Ethics and Compliance (CEC) provides for shared ownership of risk management and better coordination of risk prioritization across the company.  CEC is responsible for designing and delivering a framework to help MetLife embed compliance and ethical behaviour standards in business processes while enabling performance and growth.  In its role as a strategic advisor, CEC focuses on existing and emerging risks, partnering constructively with the businesses and functions to implement strong processes, establish effective controls, and foster a culture of compliance.  CEC monitors regulatory and industry trends and changes in order to develop and implement appropriate global and regional policies and procedures. CEC leadership includes Regional Chief Compliance Officers for EMEA, Asia, and the US & LatAm, the Head of Governance, the Head of Enterprise Compliance Programs, the Chief Compliance Officer for Investments.

MetLife Investment Management

MetLife Investment Management (MIM) is one of the largest institutional investors and asset managers in the world, with over $651 billion in combined managed assets, and has consistently generated superior returns for both policyholders and shareholders. The enterprise has more than 900 dedicated professionals with extensive experience and expertise across public and private fixed income and private assets, including real estate.  Visit us at www.metlife.com/investments to learn more.

The Role

Reporting directly to the Global Head of Compliance for Investments, the AVP, Head of Compliance for EMEA Investments, serves as the Chief Compliance Officer for MetLife Investment Management Limited (“MIML”), the regulated UK Entity of MetLife Investment Management.  The role will hold the regulatory responsibility of Financial Conduct Authority (“FCA”) Senior Manager for both the Compliance oversight and the Money laundering reporting functions (SMF16 and SMF17).  This leader will need to offer credible challenge, escalation of issues and reporting, as appropriate,  working closely with the Investments team and functional peers in Risk, Legal, and Internal Audit throughout Europe, the Middle East, and the US to implement controls and guidelines while ensuring compliance with global and regional policies, procedures and standards, laws, rules, and regulations.

The successful candidate will be responsible for the Investments compliance programs that apply to all activities of MIML personnel across the EMEA region, including  day-to-day support for Investments compliance-related questions (Gifts & Entertainment, Trading, PM, Code of Ethics, Guidelines, etc.) within the region.  This is a key position to ensure that MiFID II, GDPR, and the Senior Managers and Certification Regime have been effectively implemented across MIML and develop and sustain a right-sized and responsive governance and control environment.

In addition, this role is expected to lead Non-Financial Risk Assessment (NFRA) for EMEA region related to MIML activities, a strategically important project for Compliance.  This person will be able to lead through influence to partner effectively with the MIML teams in country to identify  non-financial risks, evaluate the existing controls, and recommend, design, and implement/action mitigation efforts appropriate to the risk assessment for each country’s operations.

This role would be expected to stay abreast of all applicable laws, rules, and regulations, proactively advising Investments leadership on implications and necessary actions.  This role will develop a clear definition of first and second line, partnering to develop appropriate risk mitigation strategies and controls, conducting monitoring and testing to ensure that all EMEA investment professionals and activities and employees comply with regulatory requirements and company standards.

We strive to attract, develop and retain diverse talent with the potential to be future leaders of our department and of MetLife as a whole. We seek compliance professionals who demonstrate intellectual capacity to understand complex matters combined with the leadership skills to motivate high performance by all our professionals. We take an active role in developing the skills of our talent and guiding their professional growth.

Key Relationships:

• Reports to:  SVP, Global Investments Compliance
• Direct reports/team: 1
• Key Stakeholders: MIM & MIML leadership & associates, Legal Affairs, EMEA Compliance, Global Financial Crimes, Global Privacy, Risk Management, Government Relations

Key Responsibilities:

Regulatory compliance

• Lead, implement, and oversee an FCA compliance program, acting as a liaison and primary oversight relationship with the FCA regarding licensing matters, regulated activity, and regulatory reporting
• Provide on-going compliance advice, counsel, and oversight to the regulated entity MIML and its personnel
• Fulfil the regulatory requirements of compliance oversight and money laundering reporting officer as defined by the FCA, i.e. SMF16 and SMF17
• Work with the business to avoid or resolve breaches and violations of regulatory policies, managing external reporting when required
• Monitor all regulatory examination findings to ensure identified control weaknesses are addressed
• Stay abreast of changes in the UK regulatory environment; educate business teams, collaborate to implement necessary changes, and maintain a current inventory of applicable laws and regulations

Strategic Investments advisory

• Develop a deep understanding of the Investments business operations, including existing and emerging products, strategies, and initiatives, in order to advise on compliance matters, identify emerging risks, anticipate regulatory developments and potential impact, and interpret policy and “grey area” exposures
• Work with Investments leaders in the “first line” to ensure continued improvement in self-identification of issues, and appropriate escalation and monitoring processes for timely and effective compliance risk mitigation or remediation
• Advise on and provide credible challenge to Investments’ compliance with relevant laws, regulations, and policies
• Act as a key contact or point of escalation for Investments associates for all compliance-related questions or concerns

Change management & program execution

• Develop and sustain a right-sized and responsive governance and control environment
• Contribute to the ongoing transformation within CEC; embrace and lead forward-looking change, collaborate on compliance best practices, and work methodically to strengthen EMEA Investments compliance coverage
• Oversee the ongoing monitoring and testing of the control environment related to key compliance risks; recommend and/or implement control enhancements when control deficiencies are identified
• Maintain and update compliance policies and procedures; ensure revisions are communicated to relevant associates
• Oversee and conduct ongoing training to reinforce the importance of the CEC program and the applicability of the CEC policies and procedures in alignment with the “three lines of defence” model for managing compliance risk
• Oversee the day-to-day administration of several key controls related to the Investments compliance program across the EMEA region, including, but not limited to, oversight of portfolio guideline monitoring, insider trading controls, market abuse monitoring, gifts and business entertainment reporting, AML, sanctions screening, regulatory reporting, and marketing material review

Cross-functional partnership

• Partner with Legal Affairs, EMEA Compliance, Global Financial Crimes, Global Privacy, Risk Management and Government Relations to understand any identified weaknesses in controls, areas of concerns, and top emerging risks; assist in developing new controls and/or processes to improve the control environment
• Build and maintain strong relationships with functional risk and legal colleagues to create a supportive and seamless compliance and ethical control culture
• Identify and communicate results of compliance risk assessments, compliance-identified issues, and control concerns to appropriate senior management including Business leaders, Risk Management, Legal Affairs and Operations officers

Candidate Qualifications:

   Essential Business Experience and Technical Skills:

• Minimum of 10 years’ experience with an FCA registered investment management firm with at least 3 years serving as Compliance Oversight and Money Laundering Reporting Officer (CF10 / SMF16 and CF11/ SMF17)
• Extensive knowledge of rules and regulations applicable to MetLife’s Investment activities in Europe, especially GDPR, MiFID II, and the Senior Managers Regime
• Understanding of institutional investment management, including products, investment guidelines and process, and other industry aspects in order to apply business acumen to interpretation of regulations
• Excellent written communication skills, including ability to write procedures, prepare formal disclosure statements and regulatory reports
• Demonstrated ability to assess risks and controls, determine when controls are not operating effectively, and act accordingly

• Excellent oral, written, and presentation communication skills at all levels; executive credibility to interact at Executive Group & Board levels as well as ability to translate complex regulations effectively to enable business understanding and solutions implementation.
• Dedicated, self-motivated professional with an ability to work independently as well as collaboratively
• Track record of designing and implementing successful training experiences Financial & business acumen, a global perspective

Preferred

• Legal background, LLB, LLM, or JD
• MBA
• Experience working in different countries

   MetLife Success Principles

• Experiment with Confidence – Courageously learn and test new ideas without fear of failure
• Act with Urgency – Demonstrate speed to action with agility and determination
• Seek Diverse Perspectives – Source ideas and feedback to expand thinking and make informed decisions
• Seize Opportunity – Drive responsible growth and identify areas for continuous improvement
• Champion Inclusion – Foster an environment where everyone is valued, heard, and can speak up
• Create Alignment – Partner with others across the organization with candour and transparency
• Take Responsibility – Be accountable and act in pursuit of the right outcomes
• Enable Solutions – Anticipate and address obstacles while managing risk
• Deliver What Matters – Execute meaningful priorities and follow through on commitments

MetLife will assist in the funding of Professional Fees for employees where it is relevant and aligned to your position within the organisation.  MetLife reserve the right to make a judgement on whether the subscription is relevant or not to your role as well as cease the payment at any time. This type of subscription will not incur “benefit in kind” tax.

SM&CR

This role is a Senior Manager role and therefore is subject to the Senior Manager and Certification Regime.  All Senior Managers are required to comply with the FCA’s Tier 1 Conduct Rules and Tier 2 Senior Manager Conduct Rules which are as follows:

Tier 1 – Individual Conduct Rules

1. You must act with integrity
2. You must act with due care, skill and diligence
3. You must be open and cooperative with the FCA, the PRA and other regulators
4. You must pay due regard to the interests of customers and treat them fairly
5. You must observe proper standards of market conduct

Tier 2 – Senior Manager Conduct Rules

1. You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively
2. You must take reasonable steps to ensure that the business of the firm for which you are responsible complies with the relevant requirements and standards of the regulatory system
3. You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively
4. You must disclose appropriately any information of which the FCA or the PRA would reasonably expect notice

MetLife:

MetLife, through its subsidiaries and affiliates, is one of the world’s leading financial services companies, providing insurance, annuities, employee benefits and asset management to help its individual and institutional customers navigate their changing world. Founded in 1868, MetLife has operations in more than 40 countries and holds leading market positions in the United States, Japan, Latin America, Asia, Europe and the Middle East.

We are one of the largest institutional investors in the U.S. with $651 billion of total assets under management as of September 30, 2020. We are ranked #48 on the Fortune 500 list for 2020. In 2020, we were named to the Dow Jones Sustainability Index (DJSI) for the fifth year in a row. DJSI is a global index to track the leading sustainability-driven companies.

MetLife is committed to building a purpose-driven and inclusive culture that energizes our people. Our employees work every day to help build a more confident future for people around the world.  Visit us at www.metlife.com to learn more about our brand, history, and values.

MetLife is dedicated to attracting, retaining, and developing a diverse and inclusive workforce. All qualified applicants will receive consideration for employment at MetLife without regards to race, colour, religion, sex (including pregnancy, childbirth, or related medical conditions), sexual orientation, gender identity or expression, age, disability, national origin, marital or domestic/civil partnership status, genetic information, citizenship status, uniformed service member or veteran status, or any other characteristic protected by law. MetLife maintains a drug-free workplace.

At MetLife, we’re leading the global transformation of an industry we’ve long defined. United in purpose, diverse in perspective, we’re dedicated to making a difference in the lives of our customers.

MetLife is proud to be an equal opportunity employer.  We are committed to attracting, retaining and maximizing the performance of a diverse and inclusive workforce.  It is the policy of MetLife to ensure equal employment opportunity without discrimination on any basis protected by law.