Senior Compliance Officer

SENIOR COMPLIANCE OFFICER (NUMÉRO DE L'EMPLOI : IFS000258)

**BNP **Paribas Asset Management Luxembourg SA (“BNP Paribas AM Lux”)** is the super manco supervising UCITS and AIF funds of the Luxembourgish BNP Paribas fund range.

**CHIEF COMPLIANCE OFFICER M/F**

**CDI**

**REPORTING LINES**: Hierarchical reporting: BNPP AM Regional Head of Compliance for Luxembourg (in Paris)

**FUNCTION**: Chief Compliance Officer in charge of the compliance function for BNP Paribas Asset

Management Luxembourg SA

**INTERACTIONS**: Conducting Officer Compliance, CEO, AM Business teams, Global AM Compliance and Domains, Territory Compliance in Luxembourg, transversal teams, BNPP AM Client Service Luxembourg coverage teams, BNPP AM Luxembourg KYC teams (Centre of Expertise)

**DEFINITION OF**_ _**RESPONSIBILITIES**

For the entity and scope under his coverage, the Chief Compliance Officer is responsible for:

- Ensuring the existence and implementation of an efficient compliance framework
- Enforcing compliance rules consistent with Group Compliance requirements and in line with applicable laws and regulations.
- Provide reasonable assurance to Global Head of BNPP AM Compliance, and BNPP AM Luxembourg CEO as well as to BNPP AM Luxembourg governance bodies and regulators that up-to-date policies and procedures, and adequate compliance set-ups are in place and applied within the entity,
- Managing a team of dedicated compliance officers.
- Acting as the named RC (Responsable du Contrôle AML/CTF) for the Management Company

The main purposes of the compliance framework are:

- To detect any risk of non-compliance with the professional obligations applicable to the entity; and
- To take any measures to minimize the consequences of non-compliance by BNPP AM Luxembourg with its professional obligations.

The Chief Compliance Officer ensures that BNP Paribas Asset Management Luxembourg framework complies with the Group rules and the Luxembourg regulations in force, in particular as regards to:

- Prevention of money laundering, fight against corruption and terrorism financing, compliance with sanctions and embargoes
- Compliance with the Professional Ethics, Market Integrity, Clients Interest’s protection and other compliance related rules
- Deployment and implementation of Compliance permanent control framework and follow-up of concrete action plans
- Deployment and/or adaptation of Compliance policies and procedures

The scope of activity covers the different activities of BNPP Asset Management Luxembourg.

**MAIN ACTIVITIES**
- **In terms of advice**
- Define the organisation and governance of the compliance framework
- Provide support and guidance to the Management and Business teams in a proactive manner and when needed or requested (e.g., RFP, due diligence visits, audits),
- Ensure that AML/CTF and customer database screening alerts are properly handled by Luxembourg Compliance
- Ensure training and advise local teams in the conduct of their mission so that they can carry out the tasks placed under their responsibility in compliance with their professional obligations
- Adapt to BNPP AM Luxembourg, the BNPP AM corporate Compliance training policy and make sure that it is tailored to local specificities, implemented, and deliver local training
- Represent the Compliance function in relevant local and global committees
- Promote staff and management awareness on Compliance topics and set the tone at the top to develop a strong Compliance culture
- **In terms of supervision**
- Ensure consistent deployment of compliance framework (policies, controls, tools, training) within BNPP AM Luxembourg
- Update the compliance risk classification in line with business developments, Group policies and regulations
- Define and regularly update applicable compliance policies, rules, standards and methodologies.
- Monitor that compliance rules are enforced in the entity and ensure that action plans are implemented to correct any weaknesses
- Make sure that the employees comply with the applicable internal rules (conduct of business, policies, training sessions ) and identify the potential situations of conflict of interests
- Advise and exercise a duty of alert with regard to the direct management and to the business lines
- Represent the Compliance Function vis a vis regulatory bodies
- Ensure regulatory watch on his/her perimeter
- **In terms of decision**
- Review at-risk clients and intermediaries files prior to their presentation to the acceptance committee
- Make Compliance decisions and/or delivers advice on the issues escalated by local teams, in his/her scope of responsibility, according to the Group decision and escalation processes
- Analyse Compliance risks and specific issues on his/her perimeter, in order to inform the decision-making bodies, to provide them with decision-making assistance and to raise alerts if the risk profile requires it
- Examine the compliance of new operations, services or products (TAC / NAC)
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