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POSITION TITLE	COMPLIANCE OFFICER - REF. NR. 0066

IMMEDIATE SUPERVISOR	CFO

GENERAL PURPOSE	The Compliance Officer establishes and implements an effective compliance program to prevent illegal, unethical, or improper conduct, monitoring and reporting results of the compliance and ethics efforts of the Trust Company and in providing guidance for Board. If necessary implement all necessary actions to ensure achievement of the objectives of an effective compliance program.

RESPONSIBILITIES	• Develops, initiates, maintains, and revises policies and procedures for the general operation of the compliance program and its related activities to prevent illegal, unethical, or improper conduct. Manages day-to-day operation of the Program. • Acts as an independent review and evaluation body to ensure that compliance issues and concerns within the organization are being appropriately evaluated, investigated, and resolved. • Monitors, and as necessary, coordinates compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends. • Identifies potential areas of compliance vulnerability and risk, develops and implements corrective action plans for resolution of problematic issues, and provides general guidance on how to avoid or deal with similar situations in the future. • Provides reports on a regular basis, and as directed or requested, keeps the Compliance Committee of the Board and senior management informed of the operation and progress of compliance efforts. • Ensures proper reporting of violations or potential violations to duly authorized enforcement agencies as appropriate or required. • Institutes and maintains an effective compliance communication program for the organization, including promoting: • heightened awareness of Standards of Conduct, an • understanding of new and existing compliance issues and related policies and procedures.

QUALIFICATIONS	• Education: Bachelor’s degree in Law required; master’s desired • Experience: A minimum of 10 years experience in a Trust/ Fund / Offshore banking organization • Skills: Demonstrated leadership ability Ability to communicate effectively orally and in writing • Knowledge: Familiarity with Trust laws, regulations, and standards Understanding of coding and reimbursement systems, risk management, and performance improvement helpful

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