Summary
The Compliance Officer provides advice and guidance to partners, lawyers and business professionals across the spectrum of risk and compliance issues as set out below.
The Compliance Officer reports directly to the HRC, with a dotted line to the OMP, and collaborates closely with the country’s General Manager (“GM”), Chief Risk and Compliance Officer (“CR&CO”), Global Head of Compliance (“GHC”), members of the Risk, Compliance, and Data Privacy teams, fellow Compliance Managers and Officers at Clifford Chance, as well as relevant Business Professional function managers. This collaborative approach ensures that the Firm fulfils its obligations in the areas outlined below.
Role
The Compliance Officer supports the OMP and GM in ensuring the compliance in the office/country and actively advises partners, other fee earners and business professionals on relevant policies, procedures and processes.
The Compliance Officer is expected to form and develop excellent working relationships with their OMP, General Manager, and other key stakeholders. Together with the OMP and GM, the Compliance Officer will implement the compliance program in Paris and Casablanca.
The Compliance Officer may from time to time be requested to take on additional responsibilities.
Key Responsibilities
The Compliance Officer's key responsibilities include the following:
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With the OMP, lead the promotion and monitoring of compliance locally, taking into account the compliance objectives set by the CR&CO.
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With the OMP or their delegate, implement preventive monitoring mechanisms with respect to compliance objectives.
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Implement a system to create awareness of Clifford Chance global policies and procedures and provide compliance advice and guidance to partners, lawyers and business professionals, including:
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Participating in the creation and review of new global policies and actively promoting awareness of and monitoring compliance with global policies in Paris and Casablanca.
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Where necessary, designing local policies that align with global policies and liaising with the HRC, GHC on any differences in local policies that may be required.
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Identifying and analysing incidences of non-compliance and implementing rectification measures.
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Advising on queries relating to gifts and hospitality and be an advisor to the central compliance team, where central compliance approval is required, in relation to any local restrictions or specific local concerns.
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Proactively identifying and assessing key regulatory and compliance risks for the office. Monitoring of the evolving compliance laws and regulations, which may have an impact on the operations of the Firm and existing policies and procedures and advise the OMP, HRC, and central compliance function of any such changes and their potential impact on the firm including through participating in horizon scanning.
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Reviewing periodic compliance reports and dashboards, ensuring appropriate follow-up by responsible stakeholders, and contributing to further enhancement of reporting methods.
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Where necessary, liaising with the local Bar or other regulators of the profession and/or support the OMP in such activities.
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Assist with local confidentiality and privilege rules, including maintaining and updating local policies and process required for compliance with these rules.
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Together with the HRC:
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Implement, operate, and develop the compliance management system, considering specific local requirements and legislation;
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Identify compliance objectives for the offices;
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Participate in implementation and monitor the development and implementation of mandatory risk and compliance training programmes;
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Develop and/or implement new standardised compliance processes, rules, and regulations;
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Develop and implement an effective system for communicating compliance topics; and
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Develop a compliance culture and raise awareness of compliance issues and the Clifford Chance Compliance Policy and Clifford Chance Code.
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Regularly reporting to the OMP, GM, HRC, and GHC on regulatory and compliance events.
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Act as a Data Privacy Contact and collaborate with global and regional Data Privacy teams to support compliance with the Firm's data privacy policy and relevant regulatory requirements, assisting in the implementation of global policies and procedures for extraterritorial regulations such as GDPR.
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In relation to anti-money laundering:
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Assist the local MLRO / MLCO or equivalent position in performing their duties, including support on suspicious activity reports (coordinating with the global AML team) and completing annual MLRO reports.
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Assisting with AML-related audits, regulator's visits, or requests.
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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.
Additional Responsibilities
Depending on the needs of the offices, the Compliance Officer may be expected to take on the following responsibilities (with training if needed):
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Together with the GM (or delegate):
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together with finance and legal teams review and assist with engagement letters, client terms, or framework agreements, supplier contracts, and other agreements and documents to be entered into by the Firm;
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closely work with and advise local finance team on compliance matters in relation to billing, time transfers, and collection.
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assist the Firm with corporate secretarial and related compliance issues.
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oversee and help with drafting and reviewing audit letters' replies before they are signed by a partner and regularly review and update templates of audit letters' replies.
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Together with the global MDR Compliance team:
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supporting DAC6/UK MDR requests and actions, as well as monitoring MDR compliance.
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ensuring an adequate level of awareness of MDR requirements, including, where necessary, conducting regular training sessions and drafting as well as maintaining up-to-date local MDR guidance.
Reporting Obligations
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Report promptly to the OMP and the HIC (and CR&CO where appropriate) on serious compliance violations in their respective country. Propose action aimed at preventing repeated violations in their respective country. Report other compliance violations promptly to offices or persons in a position to prohibit or sanction them.
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Report every six months to the HIC on compliance activities and compliance violations in their respective country.
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Report annually to the HIC on the assessment of any compliance risks which could lead to compliance violations or otherwise impair compliance objectives in their respective country.