Regulatory Consultant
Job Title: Senior Regulatory Consultant
Location: London, UK - Hybrid
Duration: 6-9 Months Contract
Job Description:
Purpose of the Role
Deliver a complete regulatory and control framework to safely design, approve, launch, and operate the above products across UK and EEA jurisdictions. This includes: regulatory perimeter/permissions analysis, regulatory engagement (FCA/NCAs), internal governance (NPA/Change Management), design of 1LoD/2LoD controls and procedures, documentation for rulebooks/terms, and implementation oversight to first live client activity.
Key Responsibilities:
1) Regulatory Perimeter & Permissions
- GlobalLink Pay (UK/EEA):
- Determine whether activities constitute payment services (e.g., execution of payment transactions, acquiring, money remittance), the correct UK PSR licensing route (e.g., API vs SPI; or leveraging bank permissions) and EEA PSD framework positioning under SSBI GmbH (or other EEA entity).
- Evaluate safeguarding requirements for relevant funds, segregation, and independent reviews; interest retention/disclosures; reconciliation cadence; and wind down provisions.
- Assess outsourcing/operational resilience for critical third parties and cross border service delivery.
- ClearConnect (Fixed Income MTF, agency counterparty set up):
- Confirm MTF permission adequacy, instruments scope, trading model (RFQ/order book/periodic), transparency, and pre/post trade obligations.
- Determine transaction reporting (MiFIR/UK MiFIR), best execution, client classification, and conflicts.
- FX Connect MTF x Digital Vega integration (options RFQ/bilateral):
- Validate venue operating conditions, derivatives scope, and market conduct (MAR) plus algo/venue controls where relevant.
- Confirm whether any rulebook amendments, technical standards, and participant agreement changes are required.
Outputs: Jurisdiction-by-jurisdiction perimeter memo, Permissions/VOP plan, regulatory obligations register, and decision logs for internal governance.
2) Regulatory Engagement & Approvals
- Lead VoP/notifications preparation (FCA/NCAs) with Legal/Reg Affairs, including drafts, evidence packs, and supervisory Q&A.
- Prepare materials for SMF approvals and Board/ExCo governance (business rationale, risk assessment, controls).
- Coordinate NPA/New Initiative approvals (front-to-back) and ensure operational resilience (impact tolerances, mapping) and outsourcing due diligence are satisfied.
Outputs: Submission-ready regulatory applications, Board/ExCo packs, NPA artefacts, regulatory engagement plan, and communications log.
3) Policy/Procedure & Control Design (1LoD/2LoD)
- Draft/update Policies (Payments, MTF Operation, MAR/Conduct, Best Ex, Client Classification, Conflicts, Outsourcing/Third Party, Records, Data Protection/Privacy, OpRes, Financial Crime AML/Sanctions).
- Produce Desk Level Procedures and Control Narratives for Product, Trading Venue Ops, Onboarding/KYC/KYB, Safeguarding, Reconciliation, Treasury/Funding flows for payments, Client Money (if applicable), and exception handling.
- Design Surveillance coverage for MTF activity (market abuse scenarios, options RFQ manipulation, pre hedging red flags, spoofing/layering, off venue bilateral behaviours), supported by MI/KRIs.
Outputs: A complete control framework (1LoD and 2LoD), procedure packs, surveillance scenarios & thresholds, and MI/KRI catalogue.
4) Documentation & Contracting
- Update MTF Rulebooks, Access & Participation Criteria, Disciplinary/Appeals, technical specs (message throttles/latency policies), and Default/Disruption procedures.
- Revise client & participant agreements, disclosures, fee schedules, best ex policy & RTS 28 style transparency (as applicable), and terms for payments (including safeguarding/fees/refunds/complaints).
- Ensure DPIAs, Records Retention schedules, and data sharing agreements (e.g., with Digital Vega) are in place.
Outputs: Redlines/final Rulebook(s), contractual templates, DPIA(s), and records schedules.
5) Implementation Readiness & Testing
- Define cut over plans, control testing (design & operating effectiveness), and surveillance dry runs using synthetic/parallel data.
- Validate reporting feeds (MiFIR/UK MiFIR, EMIR where applicable), reference data (ISINs/FIRDS/MICs), and ops workflows (recon, exception queues).
- Establish training (front office, ops, tech, compliance), first month heightened monitoring, and go live criteria.
Outputs: Go Live readiness assessment, test scripts/results, training decks, and hypercare plan.
Required Experience & Qualifications
- 10+ years in UK/EU regulatory advisory across payment services, MiFID II/MiFIR (incl. MTF operation), and derivatives trading (incl. RFQ/bilateral).
- Demonstrable experience delivering VoP/licensing outcomes with FCA and EU NCAs; drafting MTF rulebooks and participant documentation.
- Strong knowledge of UK Payment Services Regulations, EEA PSD framework, safeguarding, outsourcing and operational resilience.
- Familiarity with MAR (venue operator obligations), best execution/inducements, product governance, transaction reporting, and EMIR touchpoints.
- Comfortable with surveillance design, market conduct controls (including pre hedging detection), and algo/venue technical controls where relevant.
- Excellent document drafting, stakeholder management, and regulator facing communication skills.
Nice to have: Prior work with GlobalLink/FX platforms, Digital Vega, or fixed income electronic trading; legal qualification or prior regulator experience.