Introduction to HOLT consultancy 2016
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Transcript of Introduction to HOLT consultancy 2016
HOLT consultancy was incorporated in the DIFC as a Limited Liability Company on 30 October 2012 (DIFC license number CL1282)
Principal business activities of HOLT consultancy are to: Provide professional Compliance, risk management and governance services Provide professional training on Compliance, anti-money laundering, regulatory and reputational
issues Provide specialist recruitment services for Compliance, anti-money laundering and risk
management positions
Located in the DIFC (Office 418, Liberty House, DIFC)
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Our vision is to be the premier choice for companies when selecting a professional Compliance and risk management service provider.
Our mission is to develop our clients business through premier quality and expert execution by focussing on their needs and providing business solutions. We strive to offer a service that exceeds expectations through our commitment to our clients, adding maximum value to their business and protecting their reputation.
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As a professional Compliance services provider, we provide the following: Advice on regulatory matters New DIFC licence applications and enhancements to existing licences Compliance support Documentation (e.g. drafting manuals) Training
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Providing advice
We are able to provide your firm with advice and guidance on any particular regulatory issue or problem. Some examples of where we can provide you with advice include:
Advice on your firm’s ability to meet the DIFC and DFSA regulatory requirements Whether a particular activity constitutes a regulated activity Duties and responsibilities of Authorised individuals Business analysis advice or advice on particular issues Guidance on your firm’s policies, procedures, systems and controls Training and competence requirements Advice on regulatory risk assessments, thematic reviews or regulatory visits Advice on the set up of the Compliance function and Compliance culture This is not an exhaustive list, but advice provided can be specific to your business or generic in nature.
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Applications and authorisation
New license applications: If you are setting up a firm to conduct regulated or non-regulated business in the DIFC, we can
help you with your license application If you are setting up a regulated firm in the DIFC and you personally need to be authorised, we
are able to advise and help you with your application to become an ‘Authorised Individual’
Existing license enhancements and/or endorsements: We are able to advise and assist firms that wish to upgrade and enhance their existing license.
– Retail endorsement– Converting a Representative Office to a Category 4 – Upgrading your existing license to include a Trading Desk.
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Compliance support
Once you have clearly identified and established your Compliance needs, you may decide that you want some external support. So, depending on your circumstances, we can provide you with such support in a number of different ways, including:
Outsourced Compliance Officer, MLRO and Senior Manager. Deputy MLRO support Mentoring new or less experienced Compliance Officers/MLROs Ad hoc assistance (e.g. on a special KYC remediation project, or as a result of a negative risk assessment
or on day-to-day Compliance activities) to support an existing Compliance function that may not have sufficient headcount or experience
If you are the subject of a periodic regulatory risk assessment visit, we can provide support to your firm. Before any visit, we can:
Assist you in preparing and organising the documentation that the regulator would want to review in advance of the visit
Independently review the documentation before it is sent to the regulator Perform mock regulator interviews and provide you with constructive feedback
After any visit, we can: Guide you with any responses to the regulator to reduce the risk of any misunderstandings Assist you in your formal response to the regulator’s risk mitigation program Assist you implement any regulatory findings that may be included in the risk mitigation program
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Compliance support
Outsourced Compliance Officer, MLRO and Senior Manager
Outsourcing some or all of the Compliance function can have clear commercial advantages where the level of Compliance activity does not justify having a full-time Compliance Officer in the role, or where much of the day-to-day administration can be absorbed into an existing role but there is a requirement to have access to highly experienced Compliance professionals to advise on, and resolve, complex regulatory and compliance issues.
We can offer: A retained, outsourced Authorised Individual performing the role of Compliance Officer, MLRO and Senior Manager A short-term cover to deal with expected or unexpected absence by the incumbent Compliance Officer
Provision of an Outsourced Compliance function. Services offered will include the provision of: A suitably qualified experience Compliance Officer, MLRO and Senior Manager An appropriate Service Level Agreement based on projected scope, volume, client nature, risk analysis and other such operational matters with respect
to the satisfactory conduct of these outsourced services to you, and the relevant regulators Advice and guidance to Senior Management and the business to assist them in discharging their Compliance responsibilities Assistance Senior management and the business establish the control framework A Compliance and AML Manuals, Client Take-On procedure, Code of Conduct, policies and procedures Provide risk based monitoring Data Protection Preparation of periodic MI for regulatory and Senior Management reporting Annual Compliance Review and report Annual MLRO report Support services (including on-line subscriptions, libraries and other appropriate professional tools) to support the Compliance Officer/MLRO/Senior
Manager/Data Protection Officer Training – providing relevant periodic training Main advantages to your business: Cost effective, flexible, on demand service; Benefit from wider experience of the changing application of regulation and successful approaches in responding to this.
We will provide you with assistance in identifying qualified candidates for any permanent Compliance role.
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Documentation
We can assist you in drafting a number of documents, including:
Code of Conduct Compliance Manual Anti-Money Laundering & Counter Terrorist Financing Manual Compliance Plan and training program Policies
– risk management policy– complaints policy– personal account dealing policy– gifts and entertainment policy– financial promotions policy etc
Operating procedures (e.g. for recruitment, training and competence, complaints handling and AML. It could also include templates for disclosures)
Risk based monitoring programs This is not an exhaustive list, but all documents are tailored to your business.
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Training
Drafting of a annual Compliance training program, to include:– Provision of AML training – Provision of Conduct of Business training– Provision of Senior Management responsibilities training
Mentoring provided on an ongoing basis to junior Compliance Officers
Ben Holt is an Adjunct Lecturer for the Thomas Jefferson School of Law, San Diego, USA
Ben Holt was also a member of the ICT Middle East Training Faculty
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Ben Holt Chief Executive Officer
Ben Holt has worked in the financial services industry for 20 years and has held a number of senior international Compliance positions in London, Geneva and Dubai, in the investment banking and/or private banking divisions of HSBC, Societe Generale and Barclays. He is the founder of HOLT consultancy.
In the past 20 years, his responsibilities included the role of registered HSBC Private Bank (Suisse) SA Compliance Officer with the SWX and virt-x exchanges and licensed Compliance Officer, Money Laundering Reporting Officer and Senior Manager with the DFSA for HSBC Bank Middle East Limited, Societe Generale, NewEdge Group and Barclays Bank plc. Ben is currently the outsourced Compliance Officer/MLRO for Exotix Partners and Fisher Investments in the DIFC.
He has a Master of Science of Laws degree and is a Chartered Fellow of the Chartered Institute for Securities & Investment (CISI). He is also a Fellow member of the International Academy of Business and Financial Management (IABFM) and a Fellow member of the International Compliance Association (ICA).
Public Profile: ae.linkedin.com/pub/ben-holt/2a/988/3b7
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Natalie Hodgins Senior Compliance Officer
After graduating from Oxford, Natalie was called to the Bar in 1998. She has extensive experience in both the public and private sectors in the UK specialising in high-profile cases involving serious and organised crime, fraud and money laundering.
Consultancy work undertaken by Natalie in the past 10 years has included projects with Deloitte and the Bank of England and has focused on serious fraud prevention, anti-money laundering, Know Your Customer procedures and other compliance-related matters. Natalie’s team is currently engaged in advising clients on all aspects of compliance, anti-money laundering, risk management and governance in the insurance/reinsurance sector in the Middle East. She has successfully passed the ICA International Diploma in Compliance (with distinction) and successfully passed the Chartered Insurance Institute P97 Reinsurance module of the Insurance Diploma.
Natalie is currently the outsourced Compliance Officer/MLRO for Clements (Dubai) Limited, XL Re Europe SE, Partner Reinsurance Europe SE and Willis Limited, all in the DIFC. She also advises a number of reinsurance companies in the DIFC.
Natalie is an Associate member of the CISI.
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Shamshad Khan Senior Compliance Officer
Shamshad has worked in the financial services industry for 15 years and has held a number of senior compliance positions with various financial institutions in the insurance, asset management, investment banking and private banking sectors in Montreal, Canada and Dubai.
Most recently, Shamshad was the Regional Head of Compliance for the Private Banking division of HSBC Bank Middle East Limited, prior to which she was the Head of Compliance, MENA for Natixis Global Associates. Shamshad has also previously worked for another consulting firm in the DIFC where she was responsible for overseeing the compliance consultancy services division. Prior to relocating to Dubai in 2007, she was the Regional Compliance Officer for Manulife Financial, overseeing the company's compliance program for its insurance and securities business in the province of Quebec. Shamshad joined HOLT consultancy in February 2015.
Shamshad is currently the outsourced Compliance Officer/MLRO for Inverewe Capital, Que Capital, VTB Capital plc and Liquidity Finance LLP, all in the DIFC. She manages a team of 4 other Compliance professionals who cover compliance aspects of investment banking, private banking, asset management and funds business.
Shamshad has a Bachelor of Commerce degree in Accounting from Concordia University, Montreal, and has completed the Investment Funds course from the Institute of Canadian Bankers as well as the Officers', Partners', and Directors' Course from the Investment Funds Institute of Canada.
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Reasons for choosing HOLT consultancy include: 20+ years of international experience from blue chips such as HSBC, Societe Generale and
Barclays Excellent experience of the DIFC and DFSA. Very strong relations with the regulator Ability to offer tailor made solutions to clients Reliable, flexible and capable Client focused, dependable and timely responses to clients Strong product knowledge of banking products Newly incorporated company with capacity Located in the DIFC to be close to our clients We want to be your premier choice when selecting a professional Compliance and risk
management service provider
Awarded ‘2014 Best Consulting Firm of the Year’ at the Thomson Reuters GCC Governance, Risk and Compliance Awards
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Awarded ‘2014 Best Consulting Firm of the Year’ at the Thomson Reuters GCC Governance, Risk and Compliance Awards
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Office 418Liberty HousePO Box 506543, DIFCDubaiUnited Arab Emirates
[email protected]@holtconsultancy.com
Tel: +971 4 386 6360 Mob: +971 50 6442541
www.holtconsultancy.com
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