Benjamin Ohly Email & Phone Number

New York, Ny, Us

New York, Ny, Us

New York, Ny, Us

• Assisted the Chief Compliance Officer (CCO) in preparing and implementing the Investment Adviser’s 206(4)-7 and Fund’s 38a-1 compliance programs and reviewed Compliance policies and procedures;• Prepared Compliance board reporting for applicable governance forums, such as the Mutual Funds and ETF Board of Trustees and Ireland and Luxembourg Investment Companies;• Built and managed global cross border Compliance program, maintained policies and procedures and provided guidance to International Sales Team (APAC, EMEA, EU, LATAM) to ensure compliance with applicable private placement laws; • Led project to transition VanEck Switzerland to apply new/revised Swiss Law (Financial Services Act (“FinSA”), Financial Institutions Act (“FinIA”), Collective Investment Schemes Act (“CISA”) and its implementing ordinances and draft policies and procedures; • Was in charge of trading surveillance (IPOs, Secondary Offerings, Private Placements and Limited Investment Opportunities, Performance Disparity, Cross Trades, trade cancellations, trading errors, UK Takeover Panel);• Led cybersecurity Compliance reviews (SEC, FINRA, NFA) and remediated gaps in close collaboration with IT department; • Was in charge of Service Provider Oversight Program and conducted due diligence of sub-advisers and service providers;• Provided advice to the company’s management, investment, trading, sales and marketing teams regarding the company’s policies and regulatory requirements;• Provided Compliance training (UCITS investment restrictions, EU Short Selling Regulation etc.).• Reviewed regulatory filings including Section 13 filings, Form ADV, Canadian SEDI insider filings, international filings;• Performed Bloomberg investment restrictions surveillance including the adviser’s restricted list;• Conducted periodic and forensic compliance testing including testing of the company’s policies and procedures; reported risks to the CCO; develop remediation plans for gaps.

• Implemented, oversaw and managed Compliance program of HSBC Global Asset Management (Germany), a $30 Billion BaFin registered asset manager;• Implemented and advised on WpHG, KAGB, MaComp, MaRisk, MiFID, UCITS Directive, European Short Selling Regulation and other Directives and Regulations;• Developed and updated the Compliance Manual, policies and procedures to address compliance gaps in the organization;• Provided advice to the firm’s executives regarding regulatory requirements;• Created and implemented Compliance Risk Assessment and escalated risks to the firm’s Risk Management Committee and to the Global Head of Compliance; • Drafted, updated and implemented the firm’s Compliance review and testing plan;• Compiled Key Performance Indicators (KPIs) and Key Risk Indicators (KRIs);• Conducted periodic and forensic compliance testing including testing of the firm’s policies and procedures and reported test results to the Chief Operating Officer;• Represented the investment adviser in cross functional new product initiative meetings;• Permanent member of the firm’s Risk Management Committee, Local Product Development Committee and Investment Restrictions Committee; • Reviewed and signed-off all client facing marketing communications including website to ensure compliance with all applicable regulations;• Performed pre-trade and post trade investment restriction monitoring with Charles River (UCITS and client individual restrictions);• Conducted trading surveillance (Best Execution, Timely Execution, Large Orders, Cross Trades, Trade Aggregation and Allocation);• Acted as point of contact for Regulators, internal and external Auditors; • Conducted Compliance Trainings; • Managed two Compliance professionals;• Oversaw Compliance of subsidiary HSBC Global Asset Management (Austria).

• HSBC Alternative Investments (8 months) (structured Hedge Fund and Private Equity Funds for German institutional investors);• HSBC Global Asset Management (Deutschland) (Business Management/COO) (5 months) (assisted the COO in day to day operations);• HSBC Securities Services (5 months) (Monitored investment restrictions; wrote policies and desk procedures).

Lawyer, Law

Law, American Law