• Constantly review and control the management of ML/TF risks.
• Based on legal requirements and best practice develop framework and perform enterprise-wide risk assessment (“EWRA”) and customer risk assessment on AML/CTF and propose to the Management Board the specific measures to be taken to mitigate identified risks.
• Revise and update AML/CTF policies and procedures at least once per year, and/or on an ad-hoc basis when there are significant changes in internal processes, regulatory requirements, or AML/CTF standards.
• Review and control of the KYC onboarding process.
• Maintain required AML/CTF related logs and information within the Company.
• Assess the risk of establishing a business relationship and provide recommendations on high-risk management.
• Assess the grounds for termination of business relations and provide recommendations for the final decision.
• Review and control TM process and rules applied for AML, CTF and IS control purposes.
• Keep a record of all internal investigations carried out.
• Oversee TM implementation and ensure that the Company’s internal controls comply with guidance provided by the FCIS.
• Review and control of the ODD process.
• Create the periodic ODD log and control that periodic reviews are fulfilled on time.
• Create background for ad hoc ODD process.
• Organize and ensure the proper implementation of international sanctions control.
• Be responsible for decision to freeze of assets of sanctioned customers and/or other actions related to international sanctions control.
• Ensure that legal acts, guidelines and recommendations of LT, EU, UN, and other organisations regarding IS implementation are followed.
• Revise and update IS policies and procedures at least once per year, and/or on an ad-hoc basis when there are significant changes in internal processes, regulatory requirements, or IS standards.
• Perform periodic testing and/or evaluation of risk mitigation measures applied for international sanctions implementation within company.
• Being a key person to communicate with and timely report to relevant regulating authorities (the FCIS & the BoL).
• Taking final decision to fill SAR/STR or not.
• Be responsible for reporting IS violations cases to the FCIS.
• Be responsible for reporting on inconsistencies of internal control for IS to the BoL.
• Preparing of the quarterly reports on the actual updates of customer portfolio from AML/CTF/IS perspective to the Management Board’s consideration.
• Reporting to the Management Board regarding suspicious operations and effectiveness of AML/CTF/IS controls and procedures whenever appropriate but not less than once per quarter.
• Consulting the Management Board regarding AML/CTF/IS compliance related issues, including advice to senior management on high-risk customers from AML/CTF/IS compliance perspective.
• Duly informing all staff about the ML/TF/IS risks, including ML/TF/IS methods, trends, and typologies, and acting as the first point of escalation for all AML/CTF/IS issues from personnel.
• Keep competence and qualifications by participating in external specific trainings on AML/CTF/IS.
• Organize the AML/CTF/IS training course.
• Assess the need for additional and specialized training.
• Be responsible to draft and update yearly training plan and ensure ongoing employee education in AML/CTF and IS area.
• Participate in AML/CTF and IS internal and external audits.
• Perform other tasks related to job functions not provided for in this job description.
The MLRO is responsible for AML/CTF/IS compliance risk management in the Company and therefore, keeps up to date with ongoing legislative changes, regulatory guidance, and industry best practices in AML/CTF/IS area.
The main aim is to assess and ensure an efficient and effective internal control system for AML/CTF/IS. Aukštasis1 metai1500-2500 €