Job Summary
The Compliance Officer provides advice and guidance to partners, lawyers and business professionals across the full spectrum of risk and compliance issues as set out below.
The Compliance Officer reports to the OMP, GM, and RHC and works closely with the Global Chief Risk and Compliance Officer ("CR&CO"), Head of International Compliance ("HIC"), the Risk & Compliance team, other Compliance Managers and Officers in the global network; and relevant Business Professional function managers to ensure that the Firm meets its obligations in relation to the areas set out below.
Role
The Compliance Officer is responsible for championing and leading the compliance function in Italy and is a trusted advisor to Partners, other fee earners and business professionals on relevant policies, procedures, and processes.
The Compliance Officer must have a solid understanding of the legal industry and the applicable regulatory requirements.
The Compliance Officer is expected to form and develop excellent working relationships with OMP, GM and other key stakeholders.
Together with the OMP and GM, the Compliance Officer will implement the compliance program in Italy.
Key Responsibilities
The Compliance Officer's key responsibilities include the following:
- With the GM/OMP, lead the popularisation and monitoring of compliance locally, taking into account the compliance objectives set by the CR&CO.- With the GM/OMP or his/her delegate, implement preventive monitoring mechanisms with respect to compliance objectives.- Implement a system in the local offices to create awareness of Clifford Chance global policies and procedures and provide compliance advice and guidance to partners, lawyers, and business professionals.
This includes:
- Participating in the creation of new global policies and actively promoting awareness of and compliance with new global policies in the local office.-
- Monitoring compliance with existing global policies in the local office.-
- Where applicable, drafting local policies that align with global policies and working with the RHC/HIC on any differences in local policies that may be required, making sure the dispensation authorisation has been acquired-
- Monitoring reported incidences, reporting incidences of non-compliance and implementing rectification measures.-
- In relation to our gifts and hospitality policy:- Advise the team in Italy on queries relating to gifts and hospitality.-
- Liaise with the central compliance team on gifts and hospitality requiring central compliance approval in relation to any local restrictions or specific local concerns.-
- Monitor local regulatory changes which may have an impact on the operations of the Firm and existing policies and procedures and advise the GM/OMP and regional and central compliance function of any such changes and their impact potentially on the firm.- Identify key regulatory and compliance risks of the local offices.- Together with the RHC/HIC:
- Implement, operate and develop the compliance management system for the Milan and Rome offices taking into account specific local requirements and legislation;- Identify compliance objectives for Italy;- Monitor the development and implementation of mandatory risk and compliance training programmes;- Develop and/or implement new standardised compliance processes, rules and regulations;- Develop and implement an effective system for communicating compliance topics; and- Develop a compliance culture and raise awareness of compliance issues and the Clifford Chance Compliance Policy.- Regularly report to the GM, OMP, RHC, and HIC on regulatory and compliance matters that may arise.- Other responsibilities that may be described in the Clifford Chance Compliance Policy from time to time or which may be ancillary to the responsibilities described above.
Furthermore, the Compliance Officer is expected to take on the following:
Anti-money laundering- Support the MLRO in the discharge of his duties including, for example, providing support on Suspicious Transaction Reports (including liaising with the global team) and completion of annual MLRO report.
Data Privacy- Act as the local Data Privacy Contact ("DPC") under the Firm's Data Privacy policy, taking responsibility for Data Privacy issues arising in Italy including ensuring strict compliance with Data Privacy regulations, co-ordinating the annual Data Privacy registration process where applicable and stimulate and promote awareness of the Firm's data privacy policy.- Take responsibility for Data Privacy issues arising in Italy including ensuring strict compliance with Data Privacy regulations.- Co-ordinate the annual Data Privacy registration process where applicable and stimulate and promote awareness of the Firm's data privacy policy.- Working closely with the central compliance team, assist with the implementation of any global policies and processes in the context of extraterritorial data privacy regulations such as GDPR.
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