Climate Fund Managers (CFM) is seeking internal Risk and Regulatory Manager. The role is based in Cape Town South Africa.
CFM was established in 2015 as a joint venture between the Dutch development bank FMO based in the Netherlands and Sanlam InfraWorks – part of the Sanlam Group of South Africa. Headquartered in The Netherlands, our offices span across the emerging markets we serve, located in Singapore, South Africa, and Colombia.
As one of the leading blended finance investment managers, our business is focused on responding to the climate crisis. We use blended finance structuring to attract public and private capital to invest in high-impact sectors in emerging markets aimed at addressing the thematic areas of climate change mitigation and adaptation, including renewable energy, water and oceans, sustainable land use, and sustainable cities.
CFM’s objective is to maintain an operating environment that supports the fulfilment of obligations of a statutory, contractual, and social nature, maintain a reputation for integrity and fair dealing, and which builds and maintains confidence of Investors, Shareholders and other stakeholders.
In this role, you will be responsible for ensuring ongoing compliance with laws, regulations and industry standards, including monitoring, reviewing and implementing new regulation, legislation (in all regions CFM group operates - currently Netherlands, South Africa, Singapore and Colombia) and industry best practices so as to ensure the CFM group fulfils its statutory, regulatory and contractual obligations.
You will manage the CFM Risk Framework and particularly the KYC process to ensure the financial crime risk management policies and procedures identify and mitigate the risk of CFM becoming directly or indirectly involved in money laundering, terrorist financing, sanctions violations, tax avoidance and tax evasion (jointly referred to as tax integrity risks), corruption and bribery, fraud and financing/receiving financing from entities with a questionable reputation.
You will be responsible for ensuring regulatory and legal compliance and in particular fund mandate compliance.
- Regulatory compliance
- Keep up to date with new legal and regulation considerations, ensure key stakeholders are kept apprised of relevant regulations and/or increased regulatory risk and support implementation of processes to ensure ongoing compliance
- Drive the Regulatory Compliance risk management framework
- Provide day-to-day regulatory advice to rest of the CFM team
- Ensure compliance with AIFMD reporting/notifications including performing filings with the AFM and DNB and other regulatory authorities
- Constituent document compliance
- Maintain overview of requirements per contractual requirements of the CFM Group and funds to ensure mandate compliance with particular focus on investor side letter management
- KYC management
- Ensure adherence to the KYC Process and update (a) controls to prevent financial economic crime and (b) processes to ensure CFM has assessed the tax integrity of the parties and the associated transactions.
- Provide oversight and management of outsourced KYC screening service provider
- Risk Management
- Maintain an effective Risk Management Framework
- Manage risk assessment process and review results of the assessment to determine any remediation of controls that is required and then ensures remediation completed
- Ensure adequacy and completeness of the CFM Policy hierarchy to ensure legal and regulatory requirements met and mitigate risks inherent to each business process.
- Maintain and update the Policy Hierarchy that lists the order of precedence, with legal and regulatory requirements at the top policies, procedures, and practices to (1) respond to legal and regulatory changes and (2) ensure compliance with existing internal and industry standards
- Ensure policy updates are made and approved as required and that they are supported by effectively designed and operational controls
- Ensure there is appropriate training and communication to CFM Staff to ensure they understand their responsibilities and obligations with respect to complying with CFM policies and processes.
- Work closely with the Local Dutch Legal Counsel in respect of new regulations and laws
- Be key point of contact for the Compliance team and Internal Audit team based on the scope approved by the Audit Risk Committee
- Report to the Audit Risk Committee and the other CFM boards
Qualifications and Experience
- The right candidate will have substantive legal and operational experience in a broad spectrum of financial crime matters, with primary focus on economic sanctions in the EU, UK and the US.
- Masters in financial law
- Professional experience of 3-6 years in private practice (top tier law firm) or inhouse role in an international business environment
- Familiarity with AIFMD and Wwft
- AML/KYC experience
- International working experience
- Analytical and good communication skills and able to easily interact with colleagues and external contacts.
- Able to work as part of a wider team of geographically dispersed highly skilled professionals.
- Decisiveness -Independently making decisions and sticking to them; having the courage to make firm decisions.
- Devotion to quality -Demanding a high quality of provided products and services, and acting accordingly.
- Result-oriented -Being focused on achieving objectives and results, persevering in the face of adversity.
- Adaptability - Purposefully adapting actions to different individuals.
- Organisational sensivity - Recognising the impact of one's own decisions or actions on other parts of the organisation.
- Drive - Drive, passion.
- Analysing and forming opinions - Being focused on examining matters in a systematic way.
- Situational awareness - Demonstrate being well informed about developments in one's environment and effectively using this information for one's own organisation.