Compliance Manager

Role Summary

Reporting directly to the CCO, the Compliance Manager will operate as a Second Line function under the Three Lines Model, maintaining appropriate independence from First Line business, sales, and operations functions. The role will help build and operate an effective compliance and internal-control framework for a securities business, spanning regulatory compliance, risk, AML/CFT, trade surveillance, customer protection, marketing review, third-party oversight, and basic contract review where appropriate. The role will provide independent monitoring, challenge, advice, and timely escalation to the CCO, while partnering effectively with Legal, Risk, Business, Product, and Technology.

Key Responsibilities

• Act as a Second Line function under the Three Lines Model, maintaining independence from the First Line and providing oversight, monitoring, challenge, advice, and timely escalation to the CCO. Maintain clear separation from the Third Line (Internal Audit) while supporting appropriate coordination.
• Maintain and enhance the compliance framework under the FIEA, Financial Services Act, AML/CFT laws and regulations, FSA supervisory guidelines, and applicable SRO rules.
• Perform compliance risk assessments, monitoring, and testing; track issues and remediation; prepare clear escalation and management reporting for the CCO.
• Support the AML/CFT framework, including customer acceptance, KYC/CDD/EDD, beneficial ownership, PEP and sanctions screening, transaction monitoring, suspicious transaction escalation, risk assessment, and training.
• Conduct or support trade surveillance for potential market manipulation, insider trading, and other unfair trading; investigate alerts and maintain evidence and records.
• Review customer protection, suitability, solicitation and disclosure, advertising and marketing, conflicts of interest, complaints and incidents, anti-social forces, and information management.
• Participate in compliance reviews and launch approvals for new products, services, app functionality, and material business or process changes.
• Conduct compliance due diligence and ongoing oversight of outsourcing providers and other third parties.
• Perform first-line legal review of straightforward NDAs, vendor agreements, and outsourcing agreements, escalating material or complex issues to in-house or external counsel.
• Support the CCO in regulatory consultations, filings, inspections, and responses involving the FSA, Local Finance Bureau, and SROs; maintain policies, procedures, compliance programs, and training materials.

Required Qualifications

• 5+ years of relevant experience in Compliance, Internal Control, AML/CFT, Trade Surveillance, or a closely related function at a foreign or Japanese securities firm.
• Practical knowledge of the FIEA, FSA supervisory expectations, and key SRO rules applicable to securities firms in Japan.
• Hands-on experience in AML/CFT, KYC/CDD, transaction monitoring, and trade surveillance.
• Ability to translate regulatory obligations into policies, procedures, operational controls, and effective monitoring.
• Professional working proficiency in Japanese and English, with the ability to collaborate across Legal, Risk, Business, Product, and Technology.

Preferred Experience & Attributes

• Experience with Type I Financial Instruments Business, retail or online brokerage, FinTech, or cross-border securities activities.
• Experience with regulatory inspections or monitoring, registrations or change filings, incident and complaint handling, and compliance committee governance.
• Relevant qualifications such as JSDA representative or internal-control qualifications, or CAMS; experience reviewing straightforward Japanese and English contracts.
• High integrity and independence, balanced with commercial judgment and the ability to design practical, risk-based controls.