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Risk and Clearance
JR-2053 Requisition #

The Compliance Manager provides advice and guidance to Partners, lawyers and Business Professionals across the full spectrum of risk and compliance issues as set out below including compliance with DAC6 (MDR) regulations in Poland (and, possibly, in other offices within the CE region).
The Compliance Manager reports to the HIC, the OMP, the GM and the LCC and works closely with the Chief Risk and Compliance Officer ("CR&CO"), the Risk & Compliance team, other Compliance Managers and Officers in the global network (including DAC6 compliance team); and relevant Business Professional function managers to ensure that the Firm meets its obligations in relation to the areas set out below. 
The Compliance Manager is responsible for championing and leading the compliance function in the office and being a trusted advisor to Partners, other fee earners and Business Professionals. With in-depth knowledge of their the legal industry and the Firm's priorities, as well as being expert in business support processes, the Compliance Manager will confidently manage and own the compliance program locally. The Compliance Manager is expected to form and develop excellent working relationships with their OMP, GM, LCC and other key stakeholders (including file partners and managing associates). The Compliance Manager will work in close cooperation with the Compliance team, other risk and compliance departments, the teams dealing with matter acceptance and financial management teams. The Compliance Manager takes primary responsibility for the compliance function within the office. The Compliance Managers may from time to time be expected to take on additional responsibility and those with country responsibility may be involved in leading regional initiatives. 


Depending on the organization of compliance support within the Continental Europe Region, this role may cover other offices in the region. 
The Compliance Manager's key responsibilities include the following:

  • With the OMP, GM and LCC, lead the promotion and monitoring of compliance locally, taking into account the compliance objectives set by the CR&CO.
  • Design, develop and implement preventive monitoring mechanisms with respect to compliance objectives.
  • Leading local office efforts to create awareness of Clifford Chance global policies and procedures and provide compliance advice and guidance to Partners, lawyers and Business Professionals. This includes:
    • Participating in the creation of new global policies and actively promoting awareness of and compliance with new global policies in the local office.
    • Monitoring compliance with global policies in the local office.
    • Where applicable, designing local policies that align with global policies and liaising with the HIC on any differences in local policies that may be required.
    • Identifying and analysing incidences of non-compliance and implementing rectification measures.

In relation to our gifts and hospitality policy:

  • Advise the team in the office on queries relating to gifts and hospitality.
  • Be an advisor to the central compliance team on gifts and hospitality requiring central compliance approval in relation to any local restrictions or specific local concerns.
  • Proactively monitor local regulatory changes which may have an impact on the operations of the Firm and existing policies and procedures and advise the OMP and central compliance function of any such changes and their impact potentially on the firm.

In relation to DAC6:


  •     track progress of matters going through the relevant matter management system and address matters requiring special attention;
  •     liaise directly with managing associates and partners on their matters, addressing and managing specific questions re DAC6 compliance to local tax teams;
  •     conduct reporting to the tax authorities in the office in which you are based and assist with reporting for other CE offices where required;
  •     will regularly review the DAC6 compliance process for the office in which you are based and possibly other offices in the CE region, identifying potential areas of risks, maintaining statistics and compiling reports and cooperating with internal audit colleagues;
  •     promote awareness of DAC6 among lawyers in the CE region, assisting with training for fee-earners and ad hoc queries;
  •     keep track of developments relating to DAC6 in local regulations, primarily in the jurisdiction in which you are based and, possibly, for some other CE offices, and maintain DAC6 knowledge tools;

•    Proactively identify and assess key regulatory and compliance risks of the local office.
•    Together with the HIC:

  • Implement, operate and develop the compliance management system for the office, taking into account specific local requirements and legislation;
  • Identify compliance objectives for the office;
  • Monitor the development and implementation of mandatory risk and compliance training programmes;
  • Develop and/or implement new standardised compliance processes, rules and regulations;
  • Develop and implement an effective system for communicating compliance topics; and
  • Develop a compliance culture and raise awareness of compliance issues and the Clifford Chance Compliance Policy.

•    Regularly report to the OMP, GM, LCC and HIC on regulatory and compliance matters that may arise.
•    Other responsibilities that may be described in the Clifford Chance Compliance Policy from time to time or which may be ancillary to the responsibilities described above.

Reporting Obligations:
•    Report promptly to the OMP, GM, LCC and the HIC (and CR&CO where appropriate) on serious compliance violations in their respective country. Propose action aimed at preventing repeated violations in their respective country. Report other compliance violations promptly to offices or persons in a position to prohibit or sanction them.
•    Report every six months to the HIC on compliance activities and compliance violations in their respective country. 
•    Report annually to the HIC on the assessment of any compliance risks which could lead to compliance violations or otherwise impair compliance objectives in their respective country.

The successful candidate should meet the following criteria and have no less than 6 years prior working experience:
•    Previous experience as a Compliance professional or other experience relevant to the role and its key responsibilities.
•    Ideally, previous experience in tax or finance practice areas or a tax consultant with experience ideally gained within a professional services environment or at least some understanding of international tax concepts and principles and some knowledge of DAC6 and the EU tax regulatory environment
•    Ability to work with a wide range of stakeholders.
•    Good understanding of local bar regulations and law firms.
•    Good understanding of local anti-money laundering, anti-bribery, data privacy and insider trading regulations.
•    Experience in implementing internal policies and controls in relation to the above. 
•    Experience delivering compliance-related training.
•    Professional compliance and/or legal qualifications will be considered favourably.
•    Ability to carry out responsibilities independently and take a leadership role.

Depending on the needs of the office, the Compliance Manager may be expected to take on the following responsibilities (with training if needed):

Anti-money laundering
•    Support the MLRO in the discharge of his or her duties including, for example, providing support on Suspicious Transaction Reports (including liaising with the global team) and completion of annual MLRO report.

Data Privacy
•    Work closely with the Data Protection Officer for local entities
•    Act as the local Data Privacy Contact ("DPC") under the Firm's Data Privacy policy, taking responsibility for Data Privacy issues, including ensuring strict compliance with Data Privacy regulations, co-ordinating the annual Data Privacy registration process where applicable and stimulate and promote awareness of the Firm's data privacy policy.
•    Take responsibility for Data Privacy issues including ensuring strict compliance with Data Privacy regulations.
•    Co-ordinate the annual Data Privacy registration process where applicable and stimulate and promote awareness of the Firm's data privacy policy.
•    Working closely with the central compliance team, assist with the implementation of any global policies and processes in the context of extraterritorial data privacy regulations such as GDPR.

•    Review and assist with engagement letters, supplier contracts and other agreements and documents to be entered into by the Firm.

Audit Letters
•    Prepare and review draft audit letters before signature partner.
•    Regularly review and update template audit letters.

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