The Compliance, Money Laundering Reporting and Data Protection Officer (CO/MLRO/DPO) will be responsible for ensuring compliance with those laws, regulations and regulatory guidance that affect Harneys’ law firm in Luxembourg (Harneys Luxembourg). This role entails effective management and supervision of the Harneys Luxembourg compliance function. The CO will act as the named CO and principal liaison between the Harneys Luxembourg entity and the local regulatory authorities (in particular the Barreau de Luxembourg) with respect to Harneys compliance with established AML/CFT laws, policies and procedures. In addition the person will be the responsible Data Protection Officer for the Harneys Group.
Duties and Responsibilities:
• Maintain regulatory and operational compliance, AML/CFT, Anti-Bribery, Data Protection and other risk
related policies and procedures.
• Be responsible for the investigation of and reporting of Suspicious Activity Reports/Transactions.
Including receiving, investigating and determining the need for external disclosure of suspicions
reported by Harneys Luxembourg personnel, record decisions and maintain a SAR register.
• Provide timely and correct filing of returns to the relevant regulator.
• Prepare annual and quarterly compliance reports for the Harneys Board and to the relevant regulator
• Inform the regulator and Board where appropriate of any material compliance breaches.
• Identify, measure and assess AML/CFT and compliance risks and ensure compliance with regulatory
• Maintain, review and deliver an AML/CFT training programme.
• Act as the named MLRO principal point of contact between Harneys Luxembourg and any reporting
agencies with respect to Harneys Luxembourg compliance with established AML/CFT laws, policies
• Ensure compliance by Harneys Luxembourg and its employees with the provisions of the Luxembourg
laws and regulations including any local guidance or directive.
• Ensure compliance by Harneys Luxembourg and its employees with the provisions of any applicable
• Evaluate and where necessary prepare, amend or monitor the adequacy of anti-money laundering
policies and procedures and internal controls to ensure full compliance with all enactments relating to
• Manage relationships with fee earners and provide advice and technical support where required.
• Determine primary regulatory, compliance, financial crimes and sanctions risks.
• Support the Global Head of Compliance in Compliance Board/Committee reporting and the provision
of compliance related management Information.
• Analyse legal & regulatory changes affecting the regulatory environment and their impact on existing
policies & procedures.
• Inform and advise the business of our GDPR obligations.
• Monitor our compliance with the GDPR, including overseeing our governance structure.
• Continuing our training and awareness programs, and conducting internal audits.
• Work and cooperate with supervisory authorities, serving as their main point of contact in case of any
• Responding to and actioning data subject rights (including the rights to erasure and access).
• Continuing to review, test and finesse our policies and procedures for data protection related issues.
• Keep abreast of data protection developments in all regions where Harneys operates and make
necessary recommendations regarding compliance.
Qualifications and Experience:
• Excellent management skills with at least 3-5 years’ experience in a senior compliance and
management role in a law firm
• [Approved Person] status in at least 1 (preferably more) of the jurisdictions in which Harneys operate.
• Working knowledge of and experience with financial services regulations in multiple jurisdictions would
be an advantage
• Hold a relevant internationally recognised compliance qualification
• Excellent communication skills both written and verbal and in both English and French
• Excellent AML/CFT Training skills
• Highly computer literate
• Self-motivated and able to work without close supervision
• Effective communicator, excellent interpersonal and people management skills
• Excellent time management and ability to work under pressure
• Ability to review and implement strategy and develop the most appropriate solutions