1. Personal Details
Name Andrew Liddle
Nationality British
Address London
Summary
Qualified ACA with extensive operational audit and regulatory review experience gained in
investment and corporate banking environments.
Detailed requirement review and management of FATCA implementation including analysis of
categorisation and reporting requirements.
Review and analysis of EMIR requirements. Analysis and implementation of of reporting
requirements.
Regulatory business reviews of Fixed Income Sales & Trading; Repos; Debt Origination and
Syndication; potential conflicts across the branch, EMIR and FCA transaction reporting; client
valuations.
Analysis of FCA Best Execution expectations as they relate to bank fixed income and equities
sales and trading operations and incorporation into Execution Policies and practices.
Responsible for Compliance support of corporate banking activities including M&A,
Syndicated Loans, Leveraged Finance and Relationship Management.
Customisation and delivery of staff training modules: AML, Conflict Management, Market
Abuse, Regulatory Refresher.
Responsible for analysing regulatory requirements and providing briefing notes to business
management. Recent areas covered include:
PRA proposals on ring-fencing; FSB haircuts on non-centrally cleared securities financing
transactions; ESMA consultation on technical reporting standards under EMIR; FCA guidance
on revision of TRUP; FCA restrictions on the distribution of contingent convertible
instruments; FBA consultation on group financial support; PRA proposals on changes to
depositor protection.
Regulatory areas covered include:
PRA/FCA Principles; SYSC 10: Conflicts; APER: Code of Conduct for Approved Persons;
FIT; TC2; COBS 3: Categorisation; COBS 4: Communications; COBS 8: Client Agreements;
COBS 9: Suitability; COBS 11: Dealing & Managing; COBS 16: Reporting to Clients; COBS
22: restrictions on distribution of contingent convertible instruments; MAR 1: Code of Market
Conduct; MAR 2: Stabilisation; MAR 7: Disclosure.
Responsible for the management of teams of five to eight qualified staff in diverse business and
cultural environments including the USA, Japan, Korea, Taiwan, HK, South Africa and Canada.
Education/Qualifications
ACA Institute of Chartered Accountants in England and Wales
1980.1983 Nottingham University
BA (Hons) Economics 2:1
1978.1980 3 “A” Levels: Mathematics B; Economics B; Physics C
Chronological Employment History
2. Rabobank London June 2015 to Date
Contract Audit Manager:
Responsible for operational and regulatory audits including planning, analysis of
regulatory requirements, performing field work, identification of control weaknesses,
recommending and agreeing cost effective action plans with business management and
reporting findings and opinions to senior management.
Audits conducted: FATCA; CDD; Sanctions screening; Best Execution
Mizuho International April 2011 to May 2015
Compliance Manager responsible for:
• Briefing business management on regulatory developments and implementation
requirements;
• Project management of FATCA implementation;
• Technical analysis of EMIR requirements;
• ESMA short selling requirements; and
• Performance of regulatory business reviews.
FATCA
• Analysis of due diligence and reporting requirements under the UK / US IGA;
• Advising on bank's approach to remediation of pre-existing accounts and FATCA
compliant new account procedures including treatment of fund accounts;
• Liaising with HMRC on product specific FATCA reporting requirements: DVP;
Repos; Swaps and other Derivatives; Collateralised Agency Lending;
EMIR
• Application of the clearing objective;
• NFC clearing thresholds;
• Applicability of intra-group exemptions;
• Risk mitigations for non-centrally cleared OTC derivatives;
• Reporting to TRs;
• Recommendations on collateral requirements for non-centrally cleared OTC
derivatives.
• Review of EMIR reporting requirements
ICAAP and prudential capital reporting
• Referencing of Pillar 2 stress testing to FSA anchor scenario;
• Reverse stress testing requirements and referencing of any resulting additional
capital requirements within the ICAAP;
• Distinction between Pillar 2a and Pillar 2b requirements including explanation of
FSA calculative basis;
3. • Pillar 2a and Pillar 2b capital planning horizons;
• Adoption of forward looking hypothetical Pillar 2 scenario, movement away from
historical “1 in 25” Guidance.
Conflicts
• Review of potential conflicts arising from business activities and assessment of
policies and procedures in place to manage identified conflicts fairly including:
- Primary origination versus secondary sales and trading activity;
- Equity and fixed income sales activity versus trading;
- Agency versus custody lending;
- Fair allocation of new issues; and
- Trading ahead of block trades and research.
• Review of US agency activity including 144a sales to QIBs and issuance of
research/effecting securities transactions under Rule 15-a-6.
Sept 2010 to March 2011
Contract assignment at Rabobank International.
GFM Sales
• Client account management including methods of communication, provision and
suitability of any investment advice;
• Distribution via intermediaries;
• Off market price monitoring;
• Client order handling and monitoring of best execution obligations;
• Conflict management, including complaint handling;
• Control and reporting of sales credits.
Commodity Derivatives
• Price risk management;
• Out of hours and offsite trading;
• Market risk management including delta hedging and excess controls;
• Impact of late booked trades and trade input errors on risk positions and time
bucketed deltas;
• Trader position sign-off;
• Clearer and give-up broker reconciliations;
• Futures margin controls;
• Counterparty ISDA agreements and confirmations control;
• Counterparty credit exposure including OTC margin control;
• FOBO trade attribute and cashflow reconciliations;
• Trader P&L sign-off and independent price validation;
• Client Due Diligence Controls;
4. • Trade reporting;
• Analysis of FSA COBS requirements
• SOX script design and testing for Risk Management, Price Testing and Loans
Administration.
July 2009 to Aug 2010
Career break pursuing personal goals.
Maples and Calder
February 2009 to June 2009
Internal Audit Manager, Maples Finance Group
• Responsible for Maples Finance Group’s global internal audit function, reporting to
the Global Head of Compliance.
• Planning and co-ordination of the internal audit itinerary for the group, covering
Cayman, Dubai, Hong Kong, Dublin, Luxembourg and Jersey.
• Establishing an internal audit framework which ensures that all major risks of the
group are identified and analysed including operational, regulatory and financial
risks.
• Management of the SAS70 Type II audit in Cayman.
Personnel Sabbatical
July 2008 – January 2009
Time out to pursue personal goals.
Rabobank International
December 2000 – June 2008
Secondment to Compliance department:
• Assistance in implementation of a Product Distribution Framework, primarily
addressing look through risk in distribution of equity and fund linked notes to an
underlying retail client base;
• Completion of high level reviews across the branch of potential MiFID conflicts
and controls over insider information pertaining to UK public takeovers;
• Compliance support of Corporate banking activities including M&A, Leveraged
Finance, Relationship Management and Syndicated Loans;
• Identification and management of potential conflicts including formulation of
conflict management strategies/ implementation of deal trees in respect of more
complex deals. On-going monitoring of conflict management strategies.
Assistant Director, Internal Audit:
5. Responsible for the audit of Treasury and Capital Markets front and back office
operations including planning of audit assignments, performance of field work,
management of allocated staff, identification of control weaknesses, recommendation and
agreement of cost effective action plans with business management and reporting of
findings and opinions to senior management.
Areas covered included:
• Equity and Fund Derivatives
• Loan Syndication
• Equity Finance
• M&A
• Short Dated FX Fwds and OIS
• Medium Term FX
• Money Market Securities and Repos
• Global Financial Markets Sales and Origination;
• Proprietary trading
• Warsaw Treasury Operations
• Compliance including a review of A&O developed monitoring programme versus
FSA Rulebook
• Market Risk
• Investment research
• Logical Access controls
• P&L Valuation and Verification
• Client identification and KYC backlogs in London and Utrecht
Examples of issues addressed include:
Equity Derivatives:
• Use of unvalidated models and controls over one off transaction approvals
including monitoring of approval conditions
• Segregation of model development and validation procedures
• Controls over amendments to transaction static data during live period of a
transaction impacting economics of transaction
• Issuance and control of amended OTC confirmations arising from the above
• Accuracy of trade booking and verification and completeness of deal files
• Adequacy of P&L explainer and daily P&L sign offs
• Monitoring of spreads taken by both RI and its distributors
• Issuance and control of periodic client valuations
• Inventory of distribution agreements and implementation of Product Distribution
Framework
• Monitoring of post trade date amendments and P&L impact
• Completeness of VaR calculation based on all contributory factors
6. • Adequacy of market risk scenario analysis
• Adequacy of stress and back testing of VaR
Compliance:
• Adequacy of risk analysis compliance planning
• Conflict management including maintenance of Chinese Walls
• KYC and AML including dormant account monitoring
• Personal Account Dealing
• Receipt and best execution of customer orders
• Suitability of investment advice
• Non-Market Price Transactions
• Sanctions monitoring
• Monitoring of trading activity including large position reporting
• Inducements
• Approval and T&C
• Independence of research function
• Implementation of Chinese Wall procedures controlling analyst access to non-
public price sensitive information
• Dealing Ahead
• Research distribution
• Compliance advice
Logical Access controls:
• Delineation of responsibility for the control access framework between the
Business Owners, Information Systems and Development, Central User
Administration and the Local Security Officer.
• Consistency of access matrices across applications
• Adequacy of user re-certification
• Controls over compatibility of access rights across applications
• Redundant user Ids
• Adequacy of segregation between application development and administration
Proprietary desk:
• Controls over out of office and out of hours trading
• Market risk excess monitoring
• Completeness of FOBO reconciliations
• Daily trader P&L sign off
• Calculation of non-linear VaR on linear risk engine resulting in volatility and
gamma exposure not being calculated.
HSBC Holdings Plc
Treasury and Capital Markets Compliance Manager
7. March 1997 – December 2000
Compliance support of Debt and Capital Markets, Primary Debt origination and
syndication.
Responsible for providing Compliance solutions to business initiatives, including
resolution of conflict issues and undertaking periodic Compliance reviews of the above
activities
Projects covered included:
• Design and implementation of Chinese Wall procedures for Debt and Capital
Markets and Syndicated Finance
• Compliance support of internet based projects including a primary debt
distribution system, focusing on multi-jurisdictional and multi-entity issues
arising from the project
• Completion of an Insider Dealing investigation in South Africa
• Compliance support of internet based access to Dutch auction of corporate bonds
focusing on passporting of selling and arranging activities into other EU
jurisdictions
Audit Manager
Role involved the development of agency and principal trading audit programmes for the
investment banking operations of HSBC.
Duties:
• Responsible for the planning, management and performance of audits in the USA,
South Africa, Canada, Japan, Australia, Netherlands and the UK
• Leading teams of five to eight qualified staff on individual assignments of up to
three to five weeks
• Responsible for the allocation and management of audit resources whilst on site
based on an assessment of business unit risk
• Review and presentation of all audit recommendations to business management.
• Responsible for the production of formal audit reports for review by Senior Audit
Manager
Morgan Stanley International
Financial Auditor
July 1996 – February 1997
Prudential-Bache Securities (UK) Limited
International Audit Manager
November 1991 – July 1996
8. Initial objective of the role was to develop audit approaches for Prudential of America’s
overseas life assurance operations in Europe and the Far East together with development
and implementation of a life assurance training programme in conjunction with Coopers
& Lybrand (HK) and the Chief Internal Auditor of Royal Assurance plc.
Primary responsibility was for the audit of life assurance operations in Japan, Korea,
Taiwan, Italy and Spain. Managing teams of auditors drawn from London, Hong Kong
and the USA.
Also covered securities audits including:
• Risk management relating to proprietary trading
• Client credit management and regulatory compliance
• Retail branch reviews focusing on NYSE/SEC compliance and conformance with
House supervision, account documentation and cashiering rules. NYSE Series 7
obtained as part of this role.
• Pit and service desk trading activities
• Use and surveillance of error accounts
• Control over give-up income
• Trade confirmations
• Trade input, exchange reconciliations and margin control
• Money broker operations including collaterisation of bargains, matching and
settlement
• Review of sub-investment grade debt origination/due diligence and servicing of
the sub-investment grade book including controls over income collection and
disbursements.
Prudential Corporation
Group Internal Audit, Senior Auditor
September 1988 – October 1991
December 1987 – August 1998
Gap period travelling in the Middle East and performing conservation work in Scotland.
Peat Marwick Mclintock
April 1984 – December 1987