Compliance Surveillance Intermediate Analyst
Costa Rica
hace 2 días


The selected candidate will serves as a compliance risk analyst for Independent Compliance Risk Management (ICRM)’s Surveillance team responsible for the design, implementation, and oversight for a suite of surveillances designed to detect behaviors that may violate regulatory rules or internal policies and procedures.

When potentially anomalous behavior is detected, the team is responsible for escalating the activity and working collaboratively with partners across the first and second lines of defense to determine the appropriate resolution of the matter, which may include employee discipline.

The ICRM Global Surveillance platform encompasses a number of surveillance related portfolios including trade surveillance, e-

communications and voice surveillance, employee trading, outside activities surveillance, and information barrier surveillance.

The Employee Trading and Outside Activities team in Costa Rica, in particular, is responsible of overseeing the compliance of the LATAM population with the requirements of the Employee Personal Trading and Outside Directorship and Business Interests policies through the disclosure, pre-

clearance, statement review and annual certification process requirements managed through the Employee Due Diligence platform (EmDD).

The team is responsible for supporting the monitoring of private investments disclosures, outside activities disclosures and personal brokerage account trading for covered employees.

The surveillance process includes performing employee due diligence on personal investment accounts and / or disclosed outside activities and escalating matters appropriately to management, legal and respective product coverage areas in addition to providing input on the resolution.

The incumbent will support in addressing employee personal trading pre-clearance requests as received electronically. He / she will be responsible for developing, maintaining and performing surveillance reviews that cover specific regulations or Firm policy.

These will include risk analyses pertaining to employee participation in outside Boards, investments, and other ventures.

The analyst may also participate in ad-hoc requests, special projects and regulatory exams directed by other organizations within the compliance or legal departments.

Key Activities include :

  • Address and timely respond to employee personal trading pre-clearance requests as received via email or electronic systems (EmDD)
  • Reconciling disclosed brokerage accounts against statements uploaded by employees to identify both missing and undisclosed accounts
  • Perform enhanced due diligence on disclosed outside business activities or affiliations consistent to the requirements of the Outside Directorship and Business Interests policy.
  • Liaise with the LATAM Outside Business Activities management team and in country compliance officers regarding cross over investigations and leverage existing knowledge base to mitigate and manage potential conflict of interest risks.
  • Initiate, respond and follow up to inquiries from employees and their Supervisors with respect to the covered account population
  • Support Country Compliance Officers in requesting and complying with the ETP employee due diligence requirements such as the annual certification process, account approvals, monitoring activities among others
  • Assisting with the design and implementation of new surveillances as well as the refinement of existing ones Interacting with IT on the specific design and testing of new surveillances
  • Coordinating with both Compliance and covered employees to investigate and resolve any undisclosed or missing accounts
  • Leading team’s efforts to fulfill all duties of Records Management processes
  • Additional duties as assigned
  • Qualifications

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