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Janus Henderson Investors AML Compliance Officer - HMSA MLRO in Luxembourg

Janus Henderson Global Investors is a leading independent global asset manager, dedicated to delivering the best outcomes for clients through a broad range of actively managed funds.

We provide our institutional, retail and high net-worth individuals with access to skilled investment professionals representing a broad range of asset classes including, equities, fixed income, multi asset and alternatives.

We are a team of independent thinkers who work tirelessly to help our clients achieve their goals – and we do it by fostering an energetic and collaborative culture that ensures our people love the place they work.

Headquartered in London, Janus Henderson is a truly global asset manager with a diverse geographic footprint, managing assets from 27 offices globally and employing more than 2,000 staff.

Role:

AML Compliance Officer – HMSA MLRO

Location:

Luxembourg

Department:

Risk and Compliance

The Group

We are a leading independent global asset manager, dedicated to delivering the best outcomes for our clients through a highly diversified range of actively-managed products. We are truly global, supporting our individual and institutional investors across a range of products, encompassing equities, fixed income, multi-asset and alternatives. Our high-energy and collaborative culture at Janus Henderson helps our client achieve their goals and ensures that our people love the place they work.

The Company

Henderson Management Société Anonyme (“HMSA”), formed on 31 May 1985, is a wholly owned subsidiary of Janus Henderson Group plc (“JHG” or “JHG Group”), domiciled in Jersey. Its immediate parent undertaking is Henderson Group Holdings Asset Management Limited. HMSA is the appointed UCITS Management Company for JHG Luxembourg domiciled funds and is regulated by the Commission de Surveillance du Secteur Financier (“CSSF”). As a UCITS Management Company, HMSA, through its Board, is responsible for carrying out its duties in accordance with Chapter 15 of the Luxembourg Law of 17 December 2010 in operating and overseeing the funds, including distribution, product, investment management, operations, and risk and compliance. HMSA has been appointed as the manager for the following funds domiciled in Luxembourg: Janus Henderson Horizon Fund and Janus Henderson Fund.

In 2018, HMSA underwent a significant restructuring exercise. Four Conducting Officers and a Business Manager were appointed as well as further resources in operations and distribution, risk and compliance, and portfolio management oversight. As a consequence, the operating model of HMSA has been reviewed in line with the requirements of the CSSF Circular 18/698.

Furthermore, five new branches of HMSA have been established during 2018, with the main objective of distributing Janus Henderson Group products in their respective locations. Branches have been established in Italy (Milan); Germany (Frankfurt); Spain (Madrid); France (Paris) and Netherlands (Amsterdam).

The department

The European Compliance team comprises approximately 40 employees who oversee all business activities in UK, Europe and South America. The department works closely alongside teams in Denver and throughout Asia including significant collaboration and joint use of systems and policies.

The mission of the Compliance Department is to promote and encourage adherence to the regulatory obligations and rules to which Janus Henderson management and staff are subject. The aim is to assist the group in developing a culture where its business is conducted within both the letter and spirit of the applicable laws and regulations in the interests of our customers and to minimize the risk of reputational damage or regulatory sanction. In achieving these objectives, we will manage relationships with our regulators, provide advice and guidance to our business partners, monitor the activities performed by the group and provide training when required.

In Luxembourg, the Compliance team counts at present 2 people, granting an independent, objective oversight on the whole spectrum of activities performed by the Management Company, assuring an appropriate observance of the regulatory requirements.

Overview of the role

You will be part of the AML oversight activity, cooperating with the MLRO at Group level and the Financial Crime department globally and will be appointed as MLRO for HMSA in Luxembourg. You will report to the Risk and Compliance Conducting Office for Luxembourg.

You will be located in Luxembourg and will form a core part of the local team which includes a number of product, distribution, operations, risk and compliance professionals. The Compliance function will have a matrix reporting line to the Head of Compliance in Europe. The role will focus on EU (ex-UK) UCITS and AIF fund ranges and will offer the opportunity to be involved in major corporate projects as well as local operations.

Duties and responsibilities

You will:

  • Lead the provision of advice and guidance to the business locally on technical AML compliance queries as they arise.

  • Issue reports on Financial Crime activity, analysis and recommendations as appropriate, including to the DPs (CP86) and Conducting Officers.

  • Support the business in Luxembourg to understand the key risks and controls linked to the Financial Crime activity.

  • Assist the compliance monitoring at local level.

  • Participate with the global Compliance function on firm-wide initiatives/programs, such as the Financial Crime Department Enhancement program.

  • Oversee compliance with AML policies in Luxembourg.

  • Participate in the compliance monitoring of the established HMSA branches in Europe, taking the lead on some matters.

  • Be the designated MLRO in Luxembourg.

  • Ensure appropriate anti money laundering procedures and policies are in place, and provide staff training on them, in coordination with the department at Group level.

  • Organize and perform a constant monitoring of the AML activity against policies, provide risk assessments and reporting.

  • Develop assessment of Financial Crime risks as they relate to the relevant fund ranges.

  • Monitor, assess and address local AML regulations, including tracking new regulatory developments.

  • Prepare and submit the annual AML questionnaire required in Luxembourg.

  • Be responsible for communications and notifications to the Regulator and the Cellule de Renseignement Financier (CRF).

  • Support the Global MLRO on projects and information requests as required.

  • Carry out additional duties as assigned.

Technical skills and qualifications

  • Good working knowledge of asset management, AML oversight & compliance monitoring.

  • Detailed knowledge of applicable UCITS and AIF regulations and local regulatory environment.

  • Good knowledge of anti-money laundering rules and regulations.

  • Experience in dealing with Authorities (visits, requests, reviews) is much appreciated.

  • Sound knowledge of other CSSF and CBI regulatory requirements and principles.

  • Good IT skills, including PowerPoint, Excel.

  • Graduate preferred.

Competencies required

In addition to putting clients first, acting like an owner, and succeeding as a team, the competencies for this role include:

  • Self-starter and proactive attitude.

  • Excellent communication skills, both written and oral, with the ability to communicate effectively at all levels.

  • Ability to build and maintain relationships internally and externally.

  • Good planning, organizational and prioritization skills, and ability to assist team members with this as necessary.

  • Ability to meet tight deadlines and work in a pressurized environment, being resilient to stress.

  • Excellent team working skills, with the aim to put clients first, while assuring compliance with local and international regulations.

Ongoing competence in the role to be assessed, in line with applicable regulatory requirements, by:

  • Annual performance appraisal

  • Completion of all assigned compliance training

  • Annual attestation (Knowledge and Competence in-scope roles only)CompliancerequirementsAt a minimum the role will require you to:

  • Place the interest of Janus Henderson’s Clients first and always act in accordance with TCF (Treating Customers Fairly) principles

  • Understand and follow laws and regulations applicable for your role, seeking the help of your supervising manager or Compliance if you would like further explanation or direction regarding this

  • Understand and abide by all Janus Henderson policies applicable to your role, and ask for the support/guidance of the policy owner if you are unsure at any time

  • You are ultimately accountable for your actions and responsible for seeking further information on any or all of the above as necessary.

Janus Henderson Investors (including its subsidiaries) will not maintain existing or sponsor new industry registrations or licenses where not supported by an employee’s job functions (as determined by Janus Henderson Investors at its sole discretion).

All applicants must be willing to comply with the provisions of Janus Henderson Investors' Investment Advisory Code of Ethics related to personal securities activities and other disclosure and certification requirements, including past political contributions and political activities. Applicants’ past political contributions or activity may impact applicants’ eligibility for this position. Janus Henderson Investors is an equal opportunity / Affirmative Action employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability or veteran status. All applications are subject to background checks.

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