Quality Assurance Risk Management

Tracy-Ann Clifford CIMA, FCM

+356-******** - ****************@*******.*** - Malta

I am an experienced Compliance Officer and MLRO in iGaming companies with significant experience in the FinTech, Compliance, Regulatory, Banking, Payments and Audit Directives. Also, European Insurance Brokerage Market. I am a specialist, detecting and investigating any breaches of the Code of Business Conduct. I also monitor Compliance and Anti-Money-Laundering with the Code of Business Conduct as well as with all the other Compliance Policies and Procedures.

I have been contracting but I am now looking for a full time, fresh new challenge. I have been ‘troubleshooting’ for different Companies/Clients, making sure they are compliant [GRC] and have the necessary documentation, policies and procedures in place. I have vast experience in Risk Management and Quality Assurance Audits. I am a highly motivated individual with a very strong work ethic and I can bring a lot of experience and knowledge to any organisation. I like to make a difference and I am tenacious, loyal and extremely IT literate.

In 2011, I became a consultant/contractor and went into different companies [like Mazars] to do some very intense projects, working in the Payments, Finance, Compliance and Regulatory areas. In 2018, I moved out to Malta and have had a number of contracts such as Head of Compliance and MLRO, Operations and iGaming with significant experience in Maltese (MGA/MFSA/FIAU/MBR) Regulation and in multiple jurisdictions [MGA, UKCG, KSA, SGA, Curaçao and GGL]. Going into different start-ups, to make sure these Companies were Compliant.

I have a degree in Accounting and Law [Part LLB] and I am a qualified accountant, Certified Institute of Management Accountants [CIMA] and a Fellow of the Institute of Credit Management [FCM].

Key Skills, Training & Business Capabilities

FinTech Reporting, MIFID II, EBA, ESMA, DORA, PCI DSS, SOC2, Insurance, Re-insurance, Agile Methodology, Regulation, Compliance, MLRO, Risk Management, Key Risk Metrics SII Pillars I-III, PSD2, Data Governance, GDPR, DPO, ISO27001, SOX, Basel II, SFCR, Customer Due-Diligence, Internal/External Audits, EBA Returns, Risk Analysis, Project Management, IPO

Employment History

From February to May this year, I took part in a Sailing Regatta around Siciliy

Oct 2024 to Jan 2025 BENKO DIGITAL LIMITED, St Julian’s - TECHNICAL COMPLIANCE ANALYST - DEFINITE CONTRACT

Responsible for executing a detailed gap analysis on these start-up companies as Benko strive to grow the business. Recommend ways to reduce costs and enhance revenue: Provide advice and interpretation of technical regulations and requirements and assist in finding the cause of technical compliance issues:

Design solutions and controls to address technical issues

Interface with the regulators and external auditors and answer recent requests for information

Responsible for the licensing, accreditation and documentary and technical compliances of the company

Engaged to analyse certification support, compliance processes, issue resolution and technical testing

To cover any client communication, to offer regulatory expertise and to manage any document management

Apr 2024 to Sep 2024 TRAVELLING IN ASIA, EUROPE AND SOUTH AMERICA

I decided to go travelling to Asia, Europe [including the UK] and South America

Nov 2023 to Apr 2024 LA ROYALE GAMING INVESTMENTS LTD, St Julian’s - COMPLIANCE AND RISK - DEFINITE CONTRACT

Responsible for making sure that the iGaming companies in the Group are following all the external rules and regulations imposed by

the government mandated gaming authority:

Review, recommend improvements to and embed the governance, risk and control framework throughout the business, ensuring it remains relevant as the business changes and follows industry recognised best practices

Establish and maintain strong working relationships with business stakeholders, to ensure the risk and compliance framework is relevant and workable, particularly with respect to risk appetite across the business. Maintain the company risk register

Act as MLRO, create, review and oversee implementation of AML Policy, on-board new customers and regularly review existing ones. Provide regular AML training and awareness to employees via an e-learning platform. Manage systems and tools that facilitate the process (e.g. Creditsafe). Stay up to date with any local AML laws and regulatory changes and ensure those requirements are presented in the internal company policies and procedures, contributing to external stakeholder reporting including the Annual Report

May 2023 to July 2023 MONARCH ASSURANCE - Sliema, Malta - COMPLIANCE AND MLRO - DEFINITE CONTRACT

Responsible for the Compliance and MLRO functions for this FinTech Insurance/Re-insurance Company. The Company specialises in developing tailored life assurance products in cooperation with different business partners such as insurance brokers, asset managers, wealth planners and reinsurers:

Prepare new technology use-cases, develop and deploy to streamline into more traditional-looking finance functions

Use industry knowledge [FinTech] and secondary research to develop point of views, write thought-papers, articles and reports

Maintaining and further developing existing code bases and define task outlines and deliverables

Risk Assessments from a Risk perspective, assume and manage various levels of Risk, conducting and overseeing internal audits and periodic reviews to ensure compliance procedures are followed. Responsible for the Internal/External Audits and recommendations

Jan 2023 to Mar 2023 TRADEVIEW LIMITED - Sliema – COMPLIANCE AND RISK - DEFINITE CONTRACT

Responsible for the FinTech, Compliance and Risk functions for this Investment Management firm. The Company offers portfolio management and advisory services to individuals, payments, institutions, trusts, private funds, charitable organisations and investment companies:

Overseeing the Compliance for both in-house and 3rd-party funds and conducting initial and ongoing due diligence on investment funds

Follow up and control of MIFID II legal and operational requirements, including clients’ portfolios

Responsible for the scope as outlined in section 5.3.2 of the CSSF Circular 18/698 related to the IFM regulation for the Group, ensuring that all legal requirements and regulations are applicable

Evaluating and revising the Company’s Compliance Governance, Policies, Rules and Procedures. ensuring Compliance with (AML-CFT) requirements and meeting the requirements related to MIFID II

Aug 2022 to Dec 2022 FORTIA INTERNATIONAL - Birkirkara – COMPLIANCE AND MLRO - DEFINITE CONTRACT

I was engaged to oversee the Compliance and MLRO within the institution ensuring compliance with laws, regulatory requirements and to

produce policies and procedures. Looking after Clients Compliance needs. Reporting directly to the Board of Directors:

To ensure that the Company is compliant with Financial Intelligence Analysis Unit (FIAU), MFSA, and other pertinent regulations, detecting and investigating any breaches of the Code of Business Conduct. To report complete and accurate details of transactions to the MFSA and to act as primary contact with the FIAU, while maintaining effective relationships with other governmental bodies/agencies, handling any request or inquiry in an open and cooperative manner

Be knowledgeable on the Prevention of Money Laundering Act, (Cap. 373) and provisions amending the Act, the Regulations made thereunder, as well as the Implementing Procedures and any guidance notes issued by the FIAU. Ensure that proper Customer Due Diligence procedures are in place and the procedures for identification and verification of natural or legal persons are complied with

To ensure that the Company’s risk management policies, risk assessment profile and their application are adequately documented, maintain appropriate risk-based monitoring processes that are proportionate to the Company's operations' scale and complexity, whilst ensuring all internal suspicious activity reports received are investigated. Having the ability to exert influence over AML/CFT measures.

Jan 2022 to July 2022 YSG SAFE PROCESSING - St Julian’s - HEAD OF COMPLIANCE AND RISK - INDEFINITE

Responsible for Compliance and Risk within the institution including ensuring compliance with laws, regulatory requirements, policies and

procedures. Reporting directly to the Board of Directors of the organisation.

Designing and implementing an overall risk management process for the organisation, which includes an analysis of the financial impact on the company when risks occur

Conducting the internal investigation of compliance issues and discussing arising compliance issues with management or employees

Implementing policies and procedures to ensure that the compliance/control functions [MFSA] throughout the organisation are effective and efficient in identifying, preventing, detecting, and correcting non-compliance with applicable laws and regulations

Staying up to date with internal standards and business goals, ensuring verification and documentation

May 2021 to Jan 2022 LOCKTON INTERNATIONAL - Valletta - HEAD OF COMPLIANCE, RISK AND REGULATION - DEFINITE

This was a Maternity Cover to provide solutions to business issues, advice, train and guidance to the Malta business, ensuring that Lockton

European Brokers Limited [LEBL] [Reporting into the London, UK HO] meets the regulatory and legal requirements and effectively manages

Regulatory Risk to within the Risk Appetite:

Ensure that all financial and commercial interests of Lockton European Brokers Limited [LEBL] and the statutory objectives of the regulators [MFSA and FCA/PRA] rules are met and that compliance oversight [FCA SM16] is adhered to, AML/CFT and MLRO [FCA SM17] and Quality Assurance Audit queries and SMCR

Assist with Internal and External Audits, consider the impact of changes in the business from our regulators, market and the EC

Manage any breaches and complaints, annual business plans and ensure we have in place robust procedures to mitigate the risk of financial crime, money laundering, bribery and corruption

Managing a team of 20 Associates dealing with renewals and new and ad-hoc insurance. Review new and existing products, review of delegated authorities, TOBAs and market agreements and manage any conflict of interests

Jan 2019 to May 2019 TASIKA - Santa Venera - REGULATORY/COMPLIANCE CONSULTANT - DEFINITE CONTRACT

The opportunity arose to work with Tasika on their projects [FINREP/COREP] with the Bank of Valletta [BOV] as part of their roll out of PDS2 [Dir 2015]. Also working on MIFID2 and SMCR. Working with IT consultants remotely, responsible for making sure there was a smooth transition for PSD2 within the Bank. Ensuring that the Regulatory changes were compliant. Using Business Objects [BO] and other bespoke systems to implement these projects within the strict timescales

Apr 2017 to Sept 2018 GENERALI UK – COMPLIANCE, DATA GOVERNANCE AND CHANGE MANAGEMENT - CONTRACT

Responsible for ensuring that the UK and Group branches [9 in total] are compliant with the rules and regulations for DPA, GDPR and other Regulatory Directives, AML/CFT:

Looking at Regulatory Compliance, Data Governance, Data Quality and personal data [PII], making sure there is a program in place to record, measure, remediate and implement within agreed timescales and budget

Acting as a key player for all aspects of the company’s compliance with GDPR, including the 9 branches in Europe

Implementation of the UK and Global Data Governance and Privacy Framework

Conducting comprehensive privacy impact assessments. Drafting and updating internal policies and procedures for GDPR

Responsible for advising and supporting the sponsors and stakeholders in implementing GDPR with all respective changes required

May 2016 to Apr 2017 QBE EO PLC - London - CHANGE MANAGEMENT, DATA AND COMPLIANCE - CONTRACT

Having covered a Maternity Cover for 12 months as Head of Regulatory, I was kept on to work on several different projects as a BA/PM in Business Finance Change Management Programmes, Data Governance, Integrations, Implementations and BAU transitioning:

Assisting with the Change Management and Business Finance Transformation Programmes, Business Operations [inc. TOM and Control Framework] and Practices

Responsible for the Lead Change Management activities, providing BA input, impact analyses, risk analysis, change readiness and business document requirements, looking at processes and continuous improvement using Lean and Six Sigma methodologies

Regulatory projects including the Faster Close and Finance Transformation projects.

Apr 2015 to May 2016 QBE EO PLC - London - HEAD OF REGULATORY REPORTING, COMPLIANCE - MAT COVER CONTRACT

To assist in ensuring all existing, future Regulatory Reporting Requirements and Solvency II are met for QBE European Operations [EO].

Responsible for producing the Solvency II Pillar 3 reporting for business, coordinating inputs from actuarial, management information and finance to produce external Solvency II submissions for Pillar 3 including QRTs, SFCR and RSR, Step 1 and 2 Reviews and IMAP submission, solvency monitoring and presentation of analysis. Gap Analysis on Pillar 3 reporting requirements

Supporting on other Solvency II deliverables, liaising with Actuarial, Insurance Accounting, Financial Reporting and Risk team members, involvement in the understanding and completion of future Solvency II reporting requirements, including Data Lineage, Data Flows and input, ETL into a Strategic Tool, Standard Formula

Responsible for the Own Funds and Eligible Own Funds calculations, reporting on the Capital Position, ECR, MCR and involvement in the completion of Ratings Agency models and ORSA dashboard, responsible for the completion of FSA regulatory Returns, PRA returns.

Producing finance data for TPs, liaison with external and internal auditors, coordination of information flows for regulatory reporting requirements, ad-hoc regulatory reporting requirements, FX management and hedging

Aug 2014 to Apr 2015 CHUBB EUROPE SE - London - SOLVENCY II PILLAR 3 PROGRAMME LEAD - CONTRACT

Detailed review of existing systems and controls in place to comply with SII Pillar 3, giving advice on adequacy of financial resources and compliance. Lloyd’s Quarterly and Annual Returns, Syndicate Reporting. Completion of the Lloyd’s QMC Return, producing finance data for TPs:

Advising stakeholders and the wider finance team on areas of Solvency II, Pillars 1 - 3. Leading the delivery of Pillar 3 reporting solutions, including SAP BOFC and Oracle HFM

Coordinating the provision of financial reporting and regulatory reporting services, advising on detailed technical areas within finance, risk, compliance and financial/regulatory teams, performing process reviews, end to end business re-engineering with a focus on controls, data quality, governance and compliance

Developing Pillar 3 implementation plans with key milestones for SFCR, RSR and QRT templates, reports, data field analyses and requirements, mapping and narrative building. Design management reporting/dashboard, recommending system enhancements, upgrades or interface solutions

Feb 2014 to Aug 2014 MAZARS LLP - London - FINANCIAL CONSULTANT, REGULATORY/COMPLIANCE - CONTRACT

Senior Consultant on Regulatory, Compliance and Advisory matters, responsible for providing regulatory advisory and consultancy services.

Highly motivated and knowledgeable insurance specialist with a proven track record in financial/regulatory reporting and financial services.

Advising on detailed technical areas within finance, risk, compliance and financial/regulatory teams

Performing process reviews, end to end business re-engineering with a focus on controls, data, governance and compliance

Detailed review of existing systems and controls in place to comply with Solvency II, MiFID II, PSD2 and IFRS, developing implementation plans with key milestones, advice on adequacy of financial resources and compliance

Advising stakeholders and the wider finance team on areas of Solvency II, Pillars 1 - 3 and MiFID II, leading the delivery of reporting solutions, including SAP BOFC, Oracle HFM and other leading edge reporting solutions, coordinating the provision of financial reporting and regulatory reporting services, regional and entity reporting, key transformation requirements, dependencies and competencies, build and implement BAU processes, CRDIV new regulations, including COREP/FINREP reporting, populating new CA1-5

Jul 2013 - Feb 2014 INTER-HANNOVER GROUP - London - FINANCIAL CONSULTANT, COMPLIANCE - CONTRACT

Working as a consultant to assist in ad-hoc work for the Finance Transformation/Change Projects team, looking at Compliance, Regulatory

Reporting Systems, Solvency II and a Risk Management System:

Produce a Gap Analysis and a TOM to support the Business Functions across Finance, IT, Risk and Actuarial departments, as-is and to-be data flows, performing data gap analysis and articulating mitigation strategies, defining and documenting data

Identify where there are risks, assess and mitigate risk in accordance with the organisation’s Risk Appetite Scope and prepare a Solvency II Pillar 3 Requirements and Implementation Plan to meet the SII Regulatory Requirements

Qualitative and Quantitative Analytics, Annual and Quarterly Reporting Templates for Group and Solo Regulatory Reporting

Solvency and Financial Condition Report (SFCR) and Regularity Supervisory Report (RSR) Reporting Process, QRT Mappings and Build Out of complex Actuarial Reports, Working with Actuaries to complete QIS5 Template for Standard Formula and Internal Model and analysis of change in the Solvency Capital Requirement. SII Consolidation Reporting, SAP BOFC Consolidation for SII Reporting

Jun 2011 to Jul 2013 DIRECT LINE GROUP [Royal Bank of Scotland] - FINANCE MAJOR CHANGE PROGRAMMES, SNR PM/BA

Working as a Senior PM/BA in all areas of the business, working on their digital platform:

Reviewing different operating environments and business solutions to ensure a smooth integration process

Strategic Change and Project Manager delivering projects/programmes to time, within budget and quality

Strong problem-solving, statistical and analytical skills, with wide cross-functional experience, operating BR06 and FINREP/COREP

Involved in the IPO process for the Bank from Royal Bank of Scotland [RBS]

Delivering business analysis skills to support the Central Finance function on SOX, Solvency II and IMAP

Sep 1999 to Jun 2011 CITY UK merger [2010] with INTERNATIONAL FINANCIAL SERVICES, LONDON - FINANCE DIRECTOR

KEY STAKEHOLDERS include: Aviva, LBG, Ernst & Young, Barclays Bank, RBS Group, Clifford Chance, HMT, FCO

Liaising with finance team, management/stakeholders [Part Public/Private Sectors] to develop business processes and documentation, reviewing local market IFRS filings and reporting processes, M1 analysis and FX exposure, SAGE, TAS, assisting in the review of important UK & US GAAP / IFRS adjustments, SAP, Solvency II and Basel II

Financial management reporting for the business, including monthly, year-to-date/year-end financials, risk management including development of cash-flow reporting and ongoing bank relationship

Focussing on the definition and execution of a sustainable financial strategy, supporting long-term growth plans, senior-level role within the primary independent organisation representing the UK financial services sector

Delivered two major office relocations within a period of five years, including migration of staff and systems and developed and launched a new handbook and successfully completed two major funding tenders from the government, worth in excess of £4bn+

Feb 1993 to Sep 1999 ROHM & HAAS INTERNATIONAL - London - EUROPEAN REVENUE & NET SALES MANAGER

Appointed to senior-level sales, finance/business management role within a specialty materials company, focused on provision of financial support to assigned business units, advising on core financial and issues. Plant accounting, tax returns and financial / business status reporting for the Head Office in Philadelphia, PA. Reporting on Sales Area Profitability (SAP) to corporate HQ

Sep 1986 to Feb 1993 SES GROUP LIMITED - London - FINANCIAL CONTROLLER

Promoted through roles including Management Accountant, Credit Manager/Group Assistant Accountant. Appointed to senior-level financial leadership role within a leading UK-based engineering sector business, formulation of credit policies, compliance protocols and financial forecasts

Aug 1986 BARCLAYS BANK PLC - London - RETAIL BANKING - FAST TRACK

Academic Institution

Training Solutions Limited, Hampshire

Qualification

Prince 2 Practitioner [2002)

Institute of Directors

MIoD, Member of the Institute of Directors [2002]

Institute of Credit Management

MICM Qualified 1992 [FCM, 2002]

London School of Business

CIMA Qualified 1989

University College London

BA (Hons) in Accounting & Law 1986

Sydenham High School [GDST]

3 ‘A’ levels and 9 ‘O’ Level Qualifications

Personal Details & Additional Information

UK Citizen. Maltese Resident. Full Maltese Driving Licence

Interests include Reading, Theatre and Travelling

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