Senior Risk Officer - UK & Europe

JOB SUMMARY:

The Senior Risk Officer and Money Laundering Reporting Officer (MLRO) will be based in London and report to the Global Head of Internal Audit. This dual role encompasses responsibilities in both the second and third lines of defense, with a dotted-line reporting relationship to the Compliance Committee.

As part of the second line of defense, the role will ensure that Realty Income’s European compliance program meets all legal, regulatory, and company policy requirements concerning business conduct and financial crime matters. This includes accepting Realty Income's FCA "Nominated Officer" registration and appointment as the MLRO. The individual will be responsible for implementing and overseeing compliance policies and procedures, monitoring compliance, and providing guidance on regulatory matters.

In the third line of defense, the individual will undertake internal audit responsibilities, focusing on providing independent assurance of the effectiveness of Realty Income’s risk management, control, and governance processes. This includes performing audits and reviews, assessing internal controls, and reporting findings to the Board and senior management.

The successful candidate will play a crucial role in safeguarding the integrity and compliance of Realty Income’s operations across Europe, working collaboratively with various stakeholders to uphold the highest standards of regulatory adherence and internal controls.

This position will have a unique view of Realty Income, with a lens into all aspects of Realty Income’s audit process. As an Internal Audit management team member, the role will work closely with and report to the Global Head of Internal Audit. Internal Audit functionally reports to the Audit Committee of the Board of Directors of Realty Income Corporation, and administratively to the Chief Financial Officer. Internal Audit is part of the larger Accounting and Finance Department

Key Responsibilities:

Second Line of Defense Responsibilities:

• Financial Compliance
• Develop and manage the Anti-Money Laundering (AML) and anti-terrorist financing program, including policies and procedures, rolling out AML risk management tools and methodologies across Realty Income’s various financial counterparty relationships, developing the overall program plan, overseeing its execution, and providing regular status reports to executives and the Compliance Committee.
• Oversee the financial crime compliance program (including anti-bribery and corruption, anti-fraud, and anti-tax evasion).
• Manage the sanctions screening program in accordance with US, UK, and EU requirements.
• Arrange and deliver compliance training to team members throughout Realty Income.
• Conduct risk reviews.
• Handle regulatory reporting and relations.
• Manage compliance goals/objectives and motivate teams to achieve superior results.
• Assess internal trends and the external regulatory & law enforcement environment to make recommendations, understand risk areas, and adjust current processes.
• Oversee and/or undertake financial investigations, KYC, AML, OFAC, and sanctions reviews and collaborate with legal and other departments as appropriate.
• Collaborate with other functional areas to ensure enterprise-level finance compliance objectives are met.

• International Lending and Payments
• Serve as Realty Income’s MLRO.
• Develop policies and procedures to ensure proper safeguards are maintained throughout Realty Income regarding client onboarding and counterparty screening, in accordance with Anti-Money Laundering (AML)/anti-terrorist legislation and sanctions (including OFAC).
• Ensure proper protocol and screens are completed with foreign vendors before payments are conducted. 

Third Line of Defense Responsibilities:

• Quality Assurance:
  • Develop and implement a comprehensive Quality Assurance program focused on continuous monitoring and testing of European-based control activities.
  • Conduct quality assessments of control activities and monitor and report on the effectiveness and quality of control activities and related findings.
  • Ensure continuous improvement of control processes through feedback, training, and updated testing protocols.
  • Collaborate with internal stakeholders to address any identified deficiencies and implement corrective actions.
  • Prepare detailed reports on the outcomes of quality assurance activities and present findings to the Global Head of Internal Audit and stakeholders.

• Internal Audits:
  • Participate in the Enterprise Risk Assessment and developing a dynamic risk-based audit plan.
  • Maintain an informed perspective on organizational risks.
  • Design and lead audits to evaluate Realty Income’s strengths and the processes employed by management to effectively identify and manage risk.
  • Evaluate compliance with policies and procedures.
  • Provide value added recommendations to improve processes.
  • Identify reportable issues, perform root cause analysis, and provide remediation recommendations.
  • Ensure identified audit findings have been vetted with appropriate management.
  • Ensure audit results are presented in a clear and concise manner.
  • Monitor progress to ensure corrective actions are implemented timely.
  • Communicate results of audit and consulting projects via written reports and/or oral presentations to management.

• External Audit Coordination:
  • Assist with audits and reviews conducted by regulatory organizations.
  • Coordinate with external auditors for the consolidated audit and statutory audits, providing necessary data and documentation.

• Leadership:
  • Serve as a coach and mentor and provide opportunities for on-the-job training for Realty Income team members (including the onboarding of new team members, as needed).
  • Facilitate team meetings and training to promote continuous development and learning.
  • Work with the Global Head of Internal Audit and the Audit Management team to develop, update, and implement the department audit methodology, including all related templates, desktop procedures, and tip sheets.
  • Assist with the preparation of Realty Income Audit Committee materials and provide reports to Realty Income’s European subsidiary boards, as needed.
  • Participate in recruiting, on-boarding & development of Internal Audit personnel.
  • Promote accountability and leadership and build effective working relationships and trust with business partners across the organization.

• Other Responsibilities:
  • Train and collaborate with impacted departments on key compliance matters, particularly regarding AML, OFAC, sanctions, anti-bribery and corruption, anti-fraud, and anti-tax evasion. 
  • Research, interpret, and apply international regulations as needed. 
  • Consistently review current processes for improvement. 
  • Perform other special projects as assigned. 
  • Present updates on finance compliance, AML, sanctions, financial crime matters, and other related concepts to the Compliance Committee and the wider organization. 

Qualifications:

Knowledge, Skills, and Abilities:

• Ability to research and summarize new or newly applicable regulations/standards.
• Ability to work in a fast-paced environment and meet deadlines. 
• Must be organized, detailed, flexible, efficient, and take ownership of own work product.
• Strong verbal and written communication skills. Intermediate Microsoft Excel skills.
• Strong knowledge of Financial Crimes Compliance, such as AML, OFAC, and sanctions regulations.
• Proven ability to manage and implement compliance programs and internal audits.
• Excellent analytical, communication, and interpersonal skills.
• Proficiency with compliance and audit management tools and methodologies.
• Leadership experience of people and systems with the ability to influence at all levels.
• Written and verbal fluency in English.
• Preferred written and verbal fluency in Spanish.

Education and Experience:

• Bachelor's degree in finance, law, business, or related field.
• Professional certifications such as CA, CIA, CAMS, ICA, ACA, ACCA, or equivalent.
• Minimum of 7-10 years of experience in compliance, internal audit, or related fields.
• 5+ years of public accounting experience is preferred.
• Real estate industry experience is preferred.

Travel:

• Valid passport required.
• Expected travel approximately once per quarter.