- Responsible for compliance policy implementation within the company.
- Responsible for managing rules and procedures concerning acting as a NCO.
- Responsible for establishing legal requirements for the business model of the company, according with the specificity of the local market.
- Supports local business and Legal Department in elaborating agreements, T&C, contacts with authorities etc.
I. Monitoring of changes in legislation:
1. Daily/weekly/monthly follow up for changes and proposed changes in Russian Law, CBRF requirements (Instructions, Orders, Regulations, Recommendations), other regulators (Tax bodies, Labor Law, Roscomdanzor, etc.) and registration of applicable law changes into EXCEL table (including main fields to be fill in).
2. Preparation of separate sheets in case if changes in the Law (registered in EXCEL table) or proposed changes in the Law which requires following changes in:
- NBCI existed Policies and Procedures;
- Creation of new (earlier absent) in NBCI Policies and Procedures;
3. Address applicable changes in the Law (weekly/monthly) as result of point 1 & 2 above to the responsible departments of NBCI to confirm that:
- Department to be/is aware about changes in Law/requirements
- Department to define, confirm or update action plan/step to be taken due to changes in the Law and timeline for changes related (for example changes in Policies, procedures; changes in processes, etc.)
- In case if Department defined do not consider implementation of any changes due to Law changes, AWD with ICS decide:
a) To accept such position (no changes required) and register it into EXCEL table;
b) Escalate to Senior managements in case if position of ICS is different from Department position
- Senior Management after receiving escalation will take decision about NBCI following or not changes in the Law (earlier escalation stage)
4. Monthly/quarterly control for status of agreed changes due to changes in the Law (point 2 above):
- Chace with responsible Departments
- Escalate to Senior Management
5. Co-operate with Legal team to apply standard templates for new/updated Policies, Procedures provided by Departments before official approval by MBM, BOD.
II. Support/fieldwork with Regulatory risk assessment:
- Registration of events of Regulatory risk based on factors of this risk (exist list of factors & template of registration table:
- To be updated on monthly basis
- To be reported to MBM on quarterly basis
- Could be disclosed to BOD
- Co-operation with Compliance team (Eric) for analysis of dynamics of Customers’ complaints:
- On monthly/quarterly basis;
- Back up function for preparation of replies on Customer complaints on NBCI side (independently and in-cooperation with PP OPS team)
III. Technical support in monitoring of implementation of action plans for closing issues and violations identified by IA/ICS in 2014- 2015 years:
- On monthly basis update of control EXCEL table for each IA report steams – to collect evidence from Departments (if required) and register it in Word & EXCEL files for further presentation to IA
IV. Analysis of the economic feasibility of conclusion of contracts with legal entities and individual entrepreneurs for provision of services and/or performance of works ensuring banking transactions of the NBCI (outsourcing):
- In co-operation with Legal & Finance – only conclusion before signing new outsourcing agreement
- High Law or Economics degree;
- Experience in banking: Internal Control/Legal/Compliance;
- English - Upper-Intermediate level;
- Highly motivated to work in a international company (internal control department).