To provide expert-level regulatory advice and support to management of Cigna’s Global Employer Health business on all matters of compliance with applicable conduct of business regulatory requirements impacting the company’s current and planned future business activities.  Provide compliance input to key strategic projects as well as supporting management with the implementation of regulatory change.

In the context of the broader Cigna Europe & Global Segments business, to act as a financial crime specialist (including Anti-bribery, Anti-Money Laundering and Financial Sanctions) to ensure adequate and appropriate support is provided to management to enable them to establish and maintain effective systems and controls to mitigate financial crime risks.

Support the maintenance and embedding of Cigna Europe & Global Segments Compliance Policy Framework and a positive compliance culture, with a particular focus on financial crime-related policies.  Establish and execute appropriate mechanisms to test the continued effectiveness of policy embedding, through and ongoing program of review.   

Provide input to the development and review of the annual compliance plan to ensure it remains aligned to the key regulatory risks impacting Cigna businesses.

As a senior compliance officer, the role holder will lead or contribute to projects and initiatives.    

This role requires the combination of working in Cigna offices in the UK and home.

RELATIONSHIPS:

Working as part of a small team, the role holder will be responsible for developing and maintaining effective working relationships with a range stakeholders, including senior managers throughout Cigna Europe & Global Segments.  In relation to financial crime, this will also include building highly effective links with compliance colleagues, including within Enterprise Compliance in North America.

Support the Head of Compliance, and the European Compliance Officer in managing the relationship with regulators, including the Financial Conduct Authority, the Prudential Regulation Authority and the NBB. The role holder will work closely with the International Chief Compliance Officer and the European Chief Counsel, as appropriate.

PLANNING:

Planning and organising own workload on a daily basis and for a period up to 3 months.

JOB DIMENSIONS:

Not applicable.

KEY ACCOUNTABILITIES:

§ Provide high quality advice and guidance on matters of compliance, including conduct of business, financial crime and data protection, to business-driven projects and initiatives, ranging from local issues to complex, pan-jurisdictional, programmes of work.  Acting as regulatory expert, recommend solutions to compliance issues that are pragmatic and proportionate. 

§ Identify and review, in liaison with first-line management, regulatory developments that impact, or are likely to impact, on Cigna’s business activities to determine the actions necessary to achieve compliance.  Provide support and interpretation on regulatory rules and guidance, and undertaking gap analyses, where appropriate. 

§ Act as lead expert on financial crime activity across Europe & Global Segments (Anti-bribery, Anti-Money Laundering and Financial Sanctions), undertake periodic financial crime control assessments, and support the implementation of improvements to systems and controls, where identified.  Additionally, for financial sanctions, promptly review any potential matches against the relevant sanctions lists, e.g. OFAC, and make a determination on those that require escalation to Enterprise Compliance.  Review and assess suspicious activity reports and escalate to Head of Compliance any that may require external notification.  For the UK Branch, act as Deputy Money Laundering Reporting Officer. The financial crime responsibilities will also include providing the following support to, and oversight of, the first line of defense:

• Ensuring first line of defense resources are trained on match clearing in Europe (supervise or deliver training)
• Ensuring checks are being done so that data is flowing from all European source systems into Finscan
• Ensuring each  business unit has a testing plan and that findings are mitigated
• Acting as the local resource for match clearing questions and Finscan in general
• Acting as the local resource for sanctions/OFAC incidents

§ Maintain each of the financial crime policies, and recommend to Head of Compliance updates to policies to reflect current regulatory standards and best practice.  Assist in the review of other compliance policies.  Develop mechanisms to provide assurance on embeddedness of financial crime policies, e.g. through the collection and analysis of appropriate management information.

§ Devise effective training solutions using suitable media for the target audience, and deliver compliance training to support the embedding of compliance policies or to communicate changes to regulatory requirements.

§ Coordination and submission of financial crime reporting to the UK Regulators, and assisting in the preparation of other reporting, as required.

§ As a local Privacy Officer, provide data protection guidance and advice, including privacy breaches, to the business as required, liaising with the International Privacy Office on more complex matters or for significant privacy breaches.

§ Provide input to third party due diligence and requests for proposals on matters involving conduct of business or privacy compliance.  Maintain central records of standard responses.

§ Active promotion of a strong compliance culture and awareness of all applicable regulatory requirements impacting Cigna, with a particular focus on conduct risk and financial crime.

§ Undertake investigations into any actual or suspected breaches of regulations, principles or standards and make recommendation as to the improvement actions required to address any control weaknesses and/or achieve fair outcomes for impacted customers or members.

§ Deputise for the Head of Compliance and the European Compliance Officer, as required, e.g. attendance at meetings or making time-critical decisions in their absence.

PERSONAL SPECIFICATION

Essential

• Previous experience (minimum of six years) of working in a Compliance function within a financial services organisation, ideally within health or general insurance that has a multinational focus.

• Educated to degree level (or equivalent), ideally in Law

• Excellent understanding of the regulatory landscape applicable in to UK, and ideally across other jurisdictions across Europe.

• Strong practical knowledge of rules and guidance relating specifically to UK general insurance regulation, including conduct of business, financial crime and data protection.

• Highly developed and confident communicator, both verbally and in writing, exhibiting good questioning and listening skills.

• Consultative, approachable and persistent.  Naturally curious, good at probing facts, and challenging assumptions.

• Able to build excellent working relationships with all levels of the business through effective stakeholder management, whilst also having the ability to challenge and exert influence. 

• Ability to manage a diverse workload and prioritise tasks to meet deadlines. 

• Acts with high levels of integrity and high levels of personal and professional ethics and impartiality, displaying an open and trustworthy attitude.

• Proven analytical and problem solving ability; able to analyse and draw conclusions from a range of quantitative and qualitative information / data.

• Practical knowledge and capability with using Microsoft Office products.

• Self-motivated and confident working on own initiative as well as part of a team.

• Naturally proactive, with a bias towards driving continuous improvement activity.

Desirable

• Effectively able to undertake peer group comparisons and report on business practices against regulatory requirements, identifying areas which impact on the customer and/or business.

• To hold, or be working towards, an industry recognised qualification in compliance or a related discipline.

• A knowledge and understanding of Cigna’s products and the markets in which it does business.

• A good knowledge of internal systems and controls that apply to a regulated environment.