Marketplace Compliance Manager

Company Description

• We're ASOS. We blend our flair for fashion with our love of cutting- edge technology, but more importantly were interested in how we can bring the best out of you.

We exist to give people the confidence to be whoever they want to be, and that goes for our people too. At ASOS, you're free to be your true self without judgment, and channel your creativity into a platform used by millions.

Through our Fashion with Integrity strategy we are driving diversity, equity and inclusion across every aspect of ASOS and ensuring every ASOSer can be their authentic self at work.  We want our people to be whoever they want to be, because we believe people who bring their best selves to work, do their best work.

Job Description

About the Role

As the Marketplace Compliance Manager, you’ll focus on ASOS’ payments-related relationships and processes (for example, with acquirers and payments service providers (PSPs)). You’ll be developing and maintaining ASOS’ compliance strategy and relevant policies required to adhere to acquirer and PSP requirements and comply with applicable legislation / regulation, and ensuring that these are implemented across all relevant functions within the business in order to guarantee that ASOS maintains contractual and regulatory compliance. In collaboration with the Compliance Manager, this role will drive the implementation of compliance controls and will include a broad set of cross-functional tasks to ensure that all personnel are properly trained, processes are scalable, and metrics accurately reported.  

The Marketplace Compliance Manager’s core focus will be on four key business activities:

• Managing the contractual compliance requirements ASOS has with its PSPs and acquirers.
• Ensuring ASOS complies with applicable Marketplace rules, according to contractual and regulatory requirements.
• Managing the relationship with the card provider of ASOS’ co-branded credit card.
• Supporting ASOS in ensuring it has the right marketplace governance and compliance best practices in place.
• Supporting our culture by driving Diversity, Equity & Inclusion strategies.

What You’ll be Doing

Marketplace Compliance Monitoring

• Ensure that ASOS’ activities comply with all applicable and relevant contractual and/or legislation and regulation in relation to its marketplace, and oversee ongoing compliance with new/changing regulations and requirements relating to marketplace. 
• In collaboration with the Compliance Manager, identify financial crime compliance (FCC) vulnerabilities ASOS’ marketplace may be exposed to and implement measures to mitigate or control the risks. 

Third Party Liaison

• Ongoing review of contracts that ASOS holds with PSPs, acquirers and Capital One to ensure ASOS is fulfilling it compliance obligations under applicable regulations, such as the Marketplace Card Scheme Rules.
• Build and monitor against the Marketplace Compliance Framework, identifying areas of non-compliance with third party partners’ obligations.
• Deal with audits and audit requests conducted by and questions from our marketplace third parties (e.g. PSPs and acquirers). 

Risk management and governance

• Create, own and drive the end-to-end Marketplace Financial Crime Risk Management Framework (MFCRM).
• Manage the upkeep of FCC Policies, Processes and Procedures for ASOS Payments Limited. 
• Work with the Compliance Manager to create the financial crime risk acceptance criteria for partners and brands at ASOS. 
• In collaboration with the Compliance Manager, design and implement the company’s Customer Risk Rating (CRR) assessment model.  Define parameters of High, Medium and Low risk partners for ASOS based on factors such as ownership structure, adverse media, political exposure, high risk jurisdictions.
• Define ASOS’ customer Risk Appetite Statement (RAS) and ensure it is consistently applied across ASOS’ onboarding and KYBP review processes (both periodic and event driven).
• Support ASOS teams in keeping the know your business partner (KYBP) process fit-for-purpose and up-to-date.
• Oversee the periodic and event driven reviews of Customer Due Diligence (CDD) based on customer risk rating (High, Medium, Low).
• In collaboration with the Compliance Manager, maintain a PEP Register of all Politically Exposed Persons (PEPs) onboarded.
• Ensure Enhanced Due Diligence (EDD) is conducted on each PEP alongside a periodic KYBP refresh.
• Develop and deliver training to the business for relevant payments compliance areas (for example, Know Your Business Partner (KYBP)).  

Maintain and manage the marketplace compliance risk register

• Ensure all existing and new or potential marketplace compliance risks and issues are logged on the register and communicated to relevant parties within ASOS. 
• Conduct regular reviews of risks and issues and update these where necessary. 
• Ensure each risk or issue has a mitigation plan or control(s) assigned to it.  
• Track each risk to point of closure evidencing how each risk has been successfully mitigated / closed.  
• Ensure evidence for risk closure is full and complete, therefore providing an audit trail which can be verified by the third line of defence (3LOD).  

3 Lines of Defence

• Develop and mature the second line of defence (2LOD) by monitoring all applicable areas in relation to marketplace and the co-branded credit card.
• Support the first line of defence (1LOD) in developing and operating their own monitoring and control documentation.

Work with the Compliance Manager to ensure monitoring activity follows a consistent process across ASOS.com Limited and ASOS Payments Limited

Qualifications

Who We’d Like to Meet

Someone with:

• Demonstrable financial crime experience from a regulated entity.
• Experience working in a retail marketplace environment, specialising in marketplace compliance.
• Experience working or engaging with payment service providers and / or acquirers.
• Experience in risk identification, application of appropriate mitigating controls, and risk management.
• Knowledge of marketplace card scheme rules.
• Attention to detail when reviewing contractual obligations.
• Experience in establishing and executing compliance monitoring frameworks.
• Experience acting as a Subject Matter Expert (SME) for payments compliance queries and initiatives  

Additional Information

What’s in it for you?

• Employee discount (hello ASOS discount!)
• ASOS Develops (personal development opportunities across the business)
• Employee sample sales
• Access to a huge range of LinkedIn learning materials
• 25 days paid annual leave + an extra celebration day
• Discretionary performance related bonus scheme
• Private medical care scheme
• Flexible benefits allowance - which you can choose to take as extra cash, or use towards other benefits