Compliance Surveillance Analyst 2
Heredia, Costa Rica
hace 5 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 selected candidate will serves as a compliance risk analyst for Independent Compliance Risk Management (ICRM)’s Surveillance team responsible for

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, which 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 :

The monthly and quarterly preparation of metrics going out to several internal partners and clients (e.g. Country ICRM offices, in-

Business Risk liaisons) : reviewing, compiling, and sending out processed surveillance data covering alerts and / or BAU activity relating to firm regulations and employee trading and outside activities

Facilitate employee process of uploading statements for review

Provide general guidance to inquiries regarding EmDD

Coordinating with more senior analysts and covered employees to investigate and resolve any undisclosed or missing accounts, missing pre-

clearances, and / or pending OA disclosures as well as any policy questions pertaining to PTIP and ODBI

Gathering and organizing data to assist in the Firm’s response to inquiries received from internal and external parties governmental and exchange regulatory bodies

  • Coordinating team response to inquiries or requests from internal partners (e.g. ICRM Assurance, Internal Audit, and Legal) received via centralized channels (email, hotline)
  • Coordinating team response and management awareness of site-wide obligations, like Continuity of Business procedures, and firm-
  • wide obligations as well, like Records Management protocols

  • Additional activities including handling telephone hotlines and performing data entry in various systems.
  • Additional duties as assigned


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