Why this seat is different in Japan
The regulator reads Japanese and expects you to. Filings, inspection responses and correspondence with the Financial Services Agency (金融庁), the Securities and Exchange Surveillance Commission (証券取引等監視委員会) and the local finance bureau run in Japanese, and so do the rules of the industry associations (日本証券業協会, 投資信託協会, 日本投資顧問業協会) that bind members. A compliance head who can speak Japanese but not draft a regulatory response in it will need a deputy who can.
The role is personal. Registered financial instruments businesses must designate named individuals responsible for internal control, and those names go to the regulator. The person you hire is accountable in a way that a compliance manager in an unregulated industry is not, and the strongest candidates know exactly what they are taking on and price it.
The pool is small and circulates. Compliance professionals with asset-management or securities experience, the Financial Instruments and Exchange Act (金融商品取引法) in their fingertips and English for group reporting are a few hundred people in Tokyo. Most have been approached in the last twelve months. Counter-offers are routine.
Purpose of the role
Lead the compliance function for the Japan entity: keep the business inside the Financial Instruments and Exchange Act, association rules and group policy; manage the relationship with regulators through filings, inspections and inquiries; advise the front office in practical terms; and build a team that can carry the programme.
Key responsibilities
Regulatory advisory
- Advise investment, sales and product teams on Japanese regulatory requirements, fund and client documentation, and marketing rules.
- Interpret new regulation and association guidance and implement changes across the business.
Monitoring and reporting
- Run compliance monitoring, investment-guideline oversight and sales-practice reviews.
- Prepare and validate regulatory filings and group compliance reporting.
Regulatory engagement
- Lead inspection preparation and responses, licensing matters and regulator inquiries.
Financial crime
- Oversee anti-money-laundering and counter-terrorist-financing controls, know-your-customer, anti-social-forces (反社) screening and insider-trading controls.
Governance and culture
- Escalate and resolve compliance issues, run internal investigations and remediate control gaps.
- Deliver training and keep the compliance manual and policies current.
- Lead and develop the compliance team.
Candidate profile
Must have
- Eight or more years in compliance at a registered financial instruments business in Japan, with at least three in a leadership role.
- Detailed knowledge of the Financial Instruments and Exchange Act and the association rules relevant to the firm's registrations.
- Direct experience of a regulatory inspection or a material regulator inquiry.
- The judgement to say no to the front office and keep the relationship.
Preferred
- Legal, audit or accounting background with a professional qualification.
- Experience at both a Japanese and a foreign financial institution.
- Anti-money-laundering programme build or remediation.
Language
- Japanese at native level including reading and drafting regulatory documents.
- English at business level for group compliance, policy work and reporting. Reading and writing matter more than presentation.
Decide before you post
- Which registrations the firm holds and which named responsibilities the hire will carry.
- Reporting line to the Japan CEO, the regional CCO, or both, and who sets pay and evaluation.
- Whether legal is combined with compliance in this seat.
- The state of the programme: build, remediate or maintain. Candidates read a recent inspection finding in the JD as a warning or an opportunity depending on how you describe it.
- Hybrid arrangements, since regulator interaction and monitoring have office requirements.
How hard is this hire
Hard. The pool is small, the role carries personal accountability, and incumbents are paid to stay. Expect four to six months for a head of compliance and a counter-offer at the finish. Searches fail when the role is described as a senior manager's job and priced accordingly while the registration makes it a head's job.
Interview questions that separate candidates
- Walk me through the last inspection you handled: preparation, findings, response and what changed afterwards.
- Describe a time the front office wanted to do something you believed was not permitted. What did you do, and what happened to the relationship?
- Which association rules do you check first when a new product is proposed?
- How do you keep group policy and Japanese regulation aligned when they conflict?
- What is your own regulatory registration history and have you ever been named in a finding?
