Compliance Officer

The problem.

A proprietary firm with no outside capital sits in an unusually ambiguous place. Much of what a compliance function normally does is aimed at protecting somebody else's money. There is nobody else here. The difficulty is telling obligations that genuinely apply from ones that are inherited assumption, then meeting the first set properly rather than the second set expensively.

What you would do.

• Establish the actual obligations in each jurisdiction the firm touches, with counsel. Write down the reasoning rather than only the conclusion.
• Own the venue and banking diligence process. That is where most of the real scrutiny arrives.
• Build the surveillance and record-keeping that the obligations require, and no more.
• Own the policies that have teeth: personal dealing, confidentiality, access to the research record.
• Keep the register of what changed and why, so a diligence question two years from now is answered from a document.

What we would want evidence of.

• You have distinguished a real obligation from an inherited assumption and can describe a case where you did.
• You have taken a firm through counterparty diligence and know what they actually test.
• You write policies people follow because they are short and make sense.
• You have said no in a way that left a workable alternative on the table.
• You are comfortable with an ambiguous regulatory position and with documenting the uncertainty honestly.

What would make this a bad fit.

This role is a poor fit if you want an established framework to apply. You would be deciding which framework applies first, and defending it.

This role is a poor fit if your instinct is to import the fullest possible programme to be safe. We will disagree. The programme has to be proportionate and you have to argue for its size.