Associate III - AML KYC Specialist

Overview of Role/Principle Responsibilities:

To act as subject matter expert on all core AML/KYC due diligence activities, perform robust quality assurance and handle advanced cases, directly supporting the Analysts and providing hands-on guidance.

Key Responsibilities:

1. Advanced Due Diligence Execution

Complex Entity Review: Review and perform due diligence on non-standard, complex structures (e.g., layered ownership, trusts, foundations, offshore vehicles), ensuring full transparency of control and beneficial ownership.

Enhanced Due Diligence (EDD): Lead EDD work on high-risk clients (e.g., PEPs, complex private equity structures, high-risk geographies):

Analyse and corroborate sources of wealth and funds through documentary evidence and public record checks

Conduct in-depth open-source investigations on high-risk profiles or negative media hits

Liaise with customer agreed escalation point for enhanced approval and/or further escalation

2. Screening and Risk Mitigation

Name Screening Oversight: Validate name screening s escalated by Analysts, determine false positives and true matches, and make decisions on further escalation.

Sanctions/Adverse Media: Investigate and document all genuine matches against sanctions, PEP, and adverse media lists, with clear escalation narratives and recommendations.

3. Risk Assessment & Rating

Risk Factor Analysis: Review risk ratings assigned by Analysts, ensure scoring methodologies are correctly applied, and correct or re-assess where necessary.

KYC Reviews: Lead periodic reviews of investor files. Re-assess documentation based on trigger events—ownership changes, negative news, jurisdiction upgrade/downgrade, etc.

4. Quality Control and Training

File Review: Execute rigorous file quality checks. Maintain QA checklists, document deficiencies, and confirm corrective action by Analysts.

Coaching: Provide hands-on coaching and process clarification to Analysts and act as the first point of contact for technical queries.

Knowledge Sharing: Develop guidance notes, training materials, and best practice documentation for use within the team.

5. Analysis and Implementation

Procedure Updates: Monitor changes in AML/CFT internal procedures as required. Provide operational input to Team Leaders regarding impacts on workflows.

Project Participation: Support remediation, data clean-up, or regulatory project work as assigned.

6. Casework & Escalation

Complex Query Resolution: Act as initial escalation point for complex or unusual cases—either resolve or clearly summarise and escalate to Team Leader/Manager.

Investor & Counterparty Liaison: Handle detailed, technical queries from investors, fund managers, or distributors related to AML/KYC requirements.

7. Know your distribution (KYD) – where applicable

§In-Depth Questionnaire Analysis: Review DDQ and Wolfsberg Questionnaire responses in detail, cross-checking answers for plausibility and completeness. Follow up directly with intermediaries if clarifications are needed.

§AML Control Framework Assessment: Conduct a review and summarise the distributor’s or platform’s Financial Crime (FC) control policies and procedures, including initial and ongoing client due diligence processes. Prepare a comparison of intermediaries’ stated practices against client’s risk appetite and regulatory expectations.

§Reliance Assessment Support: Assess whether reliance on the intermediary’s AML controls may be considered, and document the findings. Where Placement Agents are involved, assist in determining if they fulfil a different role and escalate uncertainties to the designated client function.

§Investor Profile Review: Analyse and document who the underlying investors are (retail, HNWI, professional clients, etc.), as disclosed by the distributor or obtained via DDQ.

§Quality Assurance: Review Analysts’ KYD files for thoroughness and escalate deficiencies or high-risk findings as required.

Skills and Behaviours Required:

§5-6 years’ AML/KYC experience with focus on alternative investments and complex structures

§Demonstrable expertise in risk-based approaches, screening investigations, and EDD

§Adept communicator, able to articulate complex regulatory topics in practical terms

§Strong attention to detail, time management, and coaching ability

§High proficiency in KYC/AML databases and screening tools Proficiency with office productivity tools; prior exposure to KYC/AML systems advantageous.

§Strong interpersonal skills and team focus