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Group Legal and Compliance Manager - Johannesburg

Legal-Commercial
  • Ad hoc contract drafting and reviews for the Group (including negotiation of terms in most instances)
  • legal/ commercial advise to GMs across the group pertaining to interpretation of existing contractual arrangements (drafting cancellation notices/ addenda)
Compliance
  • Running KYC processes with banks
  • Ad hoc requests from auditors/ providing walk-throughs on legal processes.
  • Attendances with Gambling Board from time to time (compliance audits, queries etc.)
  • Responses to Gauteng Gambling Board re various guest complaints (including running with internal investigative processes, setting up meetings with the Board etc)
  • Applying for dispensation on behalf of specific departments and ensuring that required approval is received from the Board.
Litigation
Running with specific litigation matters from inception (LOD drafting stage) and handing same over to the attorneys if required)- monitoring progress on said matters until finalised.

Cosec
  • Running with administrative elements of quarterly Group and subsidiary board meetings (prepping agenda, minutes, submissions, setting meetings up etc, taking on cosec role in some instances)
  • Co-running LCC meetings across the Group
  • Filing annual returns on CIPC for the group
  • Ad hoc filing attendances on CIPC- disclosures/deregistration of entities.
  • Fulfilling trust secretarial/ administrative duties for Group Trusts (prepping addenda for trust deeds, advising trustees on interpretation of clauses in trust deed, attending to trustee changes at Masters Office)
Projects| Big Matters
  • Contract register- working with IT team and units to create online contract register/ running project.
  • Major transactions within group (Yellowwood +Refinance)- assisting as and when required (usually providing information to banks, prepping required resolutions, assisting with getting same approved by members of the board within required timelines)
  • Internal Control Procedures updates- working with GMs+ Ops teams to update specific ICPs for each entity (including filing same with relevant gambling boards, meeting compliance teams at the Boards and running with processes till completion/ approval)
  • Commenting on various policies and SOPs within group/ ensuring that same comply with legal requirements.
  • Legal review of directives or updates to legislation that impact the Group (including engagements with CASA/ attorneys)
Administrative
  1. Weekly / daily review and distribution of Government and Provincial Gazette Notices relevant to the industry.
  2. Raising of purchase orders for monthly invoicing from the attorneys and other suppliers being made use of.
  3. Attend to legal and compliance filing.
  4. Attend to all Subpoenas received, ensuring the requested information is provided.
  5. Attending to DOAs.
  6. Assist with auditors queries.
  7. Attend to queries and calls from across the group on various matters.
  8. Meet with the Gambling Board from time to time (audits, queries etc.)
  9. Review of daily surveillance reports and report all potential litigious matters to the insurers.
  10. Notify the insurers of any impairments and or scheduled maintenance for the group.
Credit Applications
  1. Review group credit applications.
  2. Negotiate terms on group credit applications
Agreements
  1. Review and drafting of agreements for the group. These include SLAs, EDs, SDs, Barter, Entertainment agreements etc.
  2. Negotiate terms of such agreements internally and externally until finalised.
  3. Ensure that all paperwork such as motivations etc. are signed off.
Litigation
  1. Reporting of all potential group litigious matters to the insurers, be it public liability, criminal or debtors.
  2. Instruct and brief attorneys on such litigious matters.
  3. Attend to inhouse investigations to assist attorneys and or insurers.
  4. Draft repudiation letters.
  5. Draft full and final settlement letters.
  6. Liasing with guests.
  7. Provide guidance and opinions to the group on litigious matters
  8. Compiling of the quarterly litigation schedule.
Intellectual Property
  1. Ensuring that all group trade marks are renewed timeously.
  2. Run searches for any potential infringements.
  3. Apply for any new trade marks.
  4. Instruct and work hand in hand with the IP attorneys in order to ensure that any infringements are attended to.
Debtors
  1. Attend to debtors throughout the month for the group (all administrative requirements).
  2. Drafting and sending out of LODs to all debtors for the group.
  3. Attend to full and final settlement letters as well as AODs and the negotiations thereof.
  4. Compile the monthly debtors schedules for the group and distribute same to the various units.
  5. Attend monthly debtors meeting and provide updates on progress re debtors.
  6. List debtors on ITC.
  7. Instruct debt recovery agents as well as provide support throughout the month to assist with collection of debt.
  8. Instruct the attorneys as well as provide support to assist with the collection of debt.
  9. Preparing debt write-offs and ensuring same is signed off by the relevant parties and removed from the monthly schedules.
Tenants and Lease Agreements
  1. Drafting of lease agreements as well as assist with negotiations.
  2. Ensure that bank guarantees are obtained and up to date.
  3. Drafting of Mutual Termination Agreements.
  4. Assist with collecting outstanding rental.
  5. Work with H&S and Finance in order to ensure that Tenants are compliant.
Liquor Licenses
  1. Working close with the liquor licensing agent to ensure that all group liquor licenses are renewed and paid for timeously.
  2. Attend to all group queries re liquor licenses.
  3. Attend to the appointment of Liquor License Managers across the group.
  4. Attend to the applications for occasional liquor licenses for once off events.
FICA
  1. Chair FICA meetings.
  2. Report all STR transactions as well as stained and counterfeit notes on the FIC website as discussed in the FICA Committee meeting.
  3. Drafting of FICA Committee meeting minutes, distribution thereof as well as sign off.
Compliance
  1. Drafting and submitting of all gaming requests for approval to the GGB (Surveillance changes, tables and slots promos and changes as well as all promotional events for Marketing and Entertainment)
  2. Setting up of quarterly compliance committee meeting as well as compiling of the pack and minute taking of these meetings.
  3. Receiving guest complaints lodged with the Gambling Board, investigating same and providing a response back to the Gambling Board timeously.
  4. Attending to license applications and renewals of Directors and Units such as PalaceBet.
  5. Assist with compliance and company secretarial administration duties.
  1. To ensure the group is compliant with the FIC ACT in that,
  2. RMCP (Group including Bots and PalaceBet) Ensuring compliance with the ACT and as changes take place making sure we comply by updating accordingly and getting approval from the Board.
  3. AML SOP (Group excluding PalaceBet) Updating and ensuring every AMLCO knows their responsibilities for each unit.
  4. PEP/PIP (Group)- Daily screening and making sure all positive matches are auth and records kept.
  5. UN/TFS screening (Group) Daily and live screening ensuring we comply with the ACT.
  6. Excessive Cash transactions (Group excluding BOTS + PalaceBet) (100K +) investigating all customers buying in for all amounts exceeding R100 000,00 for a Gaming Day (avg per month 174 investigations).
  7. CTR reporting (Group excluding BOTS and PalaceBet) Ensuring all transaction (50k +) gets reported to FIC with in 72h. Checking for duplication's, missed, rejected, and vailed validations. Correcting all as set out in Directive 3
  8. Irregular behavior (Group excluding BOTS and PalaceBet) To monitor and check all customers with a jump in play
  9. Customer Risk assessment (Group)- All customer must be risk assessed based on our risk Matrix
  10. SEC FIC 27,32 Sars 46 and Crime prevention 205 (Emperors only) To comply with the requested and to respond in the set timeline given.
  11. Enhance/Due Diligence (Group) Ensuring all files, High risk or political exposed customers files gets reviewed annually.
  12. Staff risk assessment (Group) All staff must be risk assessed by our risk Matrix
  13. Staff screening UN/TFS(Group)- Screening of all staff against the lists as per the ACT.
  14. Cash Desk (Group) All new accounts and tenders added to the system supporting group in no balance and system errors.
  15. KYC (Group)- Updating customer application forms and ensuring our gaming and AML systems updated the correct information as required by the ACT. (We also update PEP/PIP, source of funds and occupation)
  16. Banned Players (Group) Second check on all banned players using the casino facilities.
  17. Anonymous Players (Group) Tracking all anonymous players. (reports and updating records)
  18. System testing (Group) Avanti and CRS FIC tool we test the system regularly to ensure compliance we also have the system audited by internal audit once a year to ensure compliance.
  19. Record keeping (Emperors only)- Ensuring all records are kept, maintained in the prescribed manner.
  20. Training once the FIC ACT changes, we ensure that the RMCP is update, distributed to the group and the training system is updated to the latest version. The training department will ensure the physical training taking place.
  21. goAML - maintaining and updating as require by the ACT
  22. Areas of concern.
  23. Grand Palm- Lack of knowledge and time to resolve FIA related issues. No licenses issued as yet to assist. (Dedicated person needed to avoid penalties)
  24. PalaceBet Motivation was approved by sector head to employ a person to assist with the FIC at PalaceBet. It was decided by management that this is not needed and that PalaceBet would handle its own FIC related investigations Serious concerns on lack of reporting, investigations, and response on the goAML system. This all could lead to potential fine. These points were highlighted but rejected by management.

Predictable work
  1. Oversee the above. Anticipate issues and resolve proactively. Unplug bottlenecks in processes when they happen regardless of the cause. You will pick up bottlenecks in the weekly catchup.
  2. The quarterly work around Group board meeting prep quarterly corporate governance report informed by the workplan.
  3. Assist with subco board meeting prep where there are capacity challenges e.g. the odd additional set of minutes.
  4. Stay comfortably familiar with all litigation matters including providing feedback in the relevant management or board meetings.
  5. Legal review and oversight on all transaction/special project matters currently processes in legislation changes in a few provinces, a limited number of litigation matters, the relocations this is a lot of reading. The lawyers and economists do not have business context. Manage service provider upselling which has become far more aggressive lately.
  6. Handle complex customer complaints. Otherwise provide input on most unless they are beyond dispute.
  7. EPCOCT.
  8. Quarterly compliance matters with various gambling boards. Majority to be dealt with in March.
  9. Pref share redemption/accrued dividend alongside Charl.
  10. Manage law firm performance and billing.
  11. Manage gambling board relationships quarterly investing looks like remembering CEO birthdays and reasonably regular check-ins with key management. Do at least some quarterly e.g. the way unit visits are managed in the board meeting process.
  12. Boxing arrange attendees for stakeholder table.
  13. Follow up with application pending before the Gambling Boards for special requests.
  14. Where dispensations are not permanent e.g. NW AFS and MP security/surveillance merger, submit annual renewal.
  15. Director license renewal. Usually involves filling forms for them.
  16. Run transactions on Oneworld as needed.
  17. BEE Ownership element first 4 months of the year usually. May be detailed or abridged depending on the age of supporting documents. This year it is detailed.
  18. Manage Resolves delivery.
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