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Janus Henderson Investors Senior Transfer Agency and Financial Crime Oversight Analyst in Luxembourg

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 department

Henderson Management S.A. (“HMSA”) is the appointed UCITS Management Company for JHI Luxembourg and Irish domiciled funds and AIFM for a number of EU domiciled alternative funds and is regulated by the Commission de Surveillance du Secteur Financier (“CSSF”). HMSA operates an outsourced model in partnership with our Third-Party Administrators (TPA). The primary focus of the Operations team is the oversight and management of the TPAs as well as supporting internal clients (for example the Distribution and Investment teams). Operations also support numerous projects and operational changes to maintain best practice operational processes.

Overview of the role

This role has two key areas of responsibility:

1) Day to day operational financial crime prevention (“FCP”) activities, primarily:

  • the establishment of JHI’s Financial Crime Risk Assessment (“FCRA”) process for Distributors and Intermediaries;

  • the application of the firm’s anti-money laundering policy to operational transfer agency processes which will include oversight of outsourced functions to third party administrators.


2) TA Oversight:

  • monitor and manage service standards provided by TA (including SLAs and KPIs) to ensure excellent client service is delivered.

You will be located in our Luxembourg office, and will work alongside a number of distribution, operations, investment, risk and compliance professionals. You will have the opportunity to be involved in major corporate projects as well as local operations.

You will be influential in meeting our corporate guiding principle of putting our clients at the heart of everything we do as well as ensuring we meet regulatory responsibilities whilst striving to continually evolve and improve our operational FCP model.

The role oversees funds under the HMSA Management Company (Luxembourg SICAVs, Irish Funds and European Alternative funds) and includes the provision of support to the HMSA Conducting Officer (CO) responsible for Operations and Distribution Oversight (e.g. from a reporting and procedures perspective) and has a functional reporting line to the Manager of the Financial Crime Operations team in London.

Duties and responsibilities

Distributor Due Diligence

You will:

  • Carry out the day to day process for issuing and chasing FCRA questionnaires, including an initial roll-out to our third party distributors;

  • Assisting with the initial assessment of distributors and intermediaries, and liaising with the Financial Crime team as appropriate;

  • Ongoing screening of distributors and intermediaries as appropriate;

  • Assisting with the assessment of the distributor/intermediary risk rating and recommendation to upgrade if appropriate;

  • Prepare all necessary papers for submitting higher risk distributors / intermediaries for approval by senior management;

  • Completing FCRA on distributors and intermediaries based on completed questionnaires.

Operational Financial Crime Prevention Activities

You will:

  • Assist with investor screening activities (sanctions, PEPs, adverse media), some of which are outsourced to third party administrators;

  • Be actively involved in investor due diligence activities, some of which might manifest as re-ID projects led by our third party administrators;

  • Undertake transaction monitoring activities including reporting and internal escalation;

  • Assist with the implementation of operational change related to financial crime prevention which could be generated internally, by our third party administrators and also by regulatory / industry change.

TA Oversight

You will:

  • Monitor and validate the investor tax reporting on an annual basis;

  • Undertake quarterly reviews of the management company rebate process;

  • Support the client complaints handling process;

  • Coordinate Ongoing monitoring and periodic due diligence of the TPA(s) including:

  • Monthly Service Review Calls and TPA Governance Meetings

  • Review and assessment of KPIs and SLAs

  • Support the CO in the delivery of reporting to HMSA Management Committee and HMSA and Funds Boards covering Operations / Distribution;

  • Assist in the provision of regulatory reporting to the CSSF, CBI and other local regulators as may be required from time to time;

  • Ensure a robust governance framework (including relevant procedures) is maintained.


You will:

  • Build direct relationships with our transfer agencies, distributors / intermediaries, and with sales, financial crime compliance teams and legal teams within Janus Henderson.

  • Develop and support additional FCRA responsibilities (extended regulation or further jurisdictional requirements) as required

  • Continuously seek to identify operational efficiencies in the team’s processes.

  • Carry out additional duties as assigned.

  • Report to the Conducting Officer responsible for Operations and Distribution with a functional reporting line to the Manager of the Financial Crime Operations team

  • Support and execute the Financial Crime Operations processes/procedures, systems and controls

  • Carry out additional duties as assigned.

Supervisory responsibilities

  • No

Technical skills and qualifications

  • Prior experience of TA oversight and knowledge of financial crime (e.g. due diligence, screening, KYC)

  • Very good working knowledge of investment funds and products and their distribution

  • Fluent written and spoken English required and other languages an advantage

  • Good IT skills, including PowerPoint, Word and Excel.

Competencies required

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

  • Strong analytical skills and attention to detail

  • Highly organised

  • Ability to work under pressure and to tight deadlines

  • Good communication skills, both verbal and written, and the ability to liaise with senior management, peers and other team members

  • At ease with multiple reporting lines built on a matrix organisation

  • Committed team player

  • Prepared to work hard and will enjoy the challenges of a fast moving and changing environment

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)

Compliance requirements

At a minimum the role will require you to:

  • Place the interest of Janus Henderson’s Clients first, 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 additional guidance is required

  • Understand and abide by all Janus Henderson policies applicable to your role, and seek support/guidance of the policy owner guidance when required

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

Janus Henderson (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 at its sole discretion).

All applicants must be willing to comply with the provisions of Janus Henderson 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 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.