Role Purpose
Senior Manager- Compliance Operations- Demat will be responsible for ensuring end-to-end regulatory and operational compliance of Demat and Depository Participant activities, with specific responsibility for CDSL compliance, system controls, cyber-security audits, regulatory inspections, operational risk management and closure of audit observations. The role will act as a key interface between Business, Demat Operations, Technology, Information Security, Internal Audit, CDSL, SEBI and other regulatory stakeholders.
Key Responsibilities
A. CDSL & Depository Compliance
Ensure compliance with applicable SEBI regulations, CDSL Bye-Laws, Operating Instructions, circulars and guidelines.
Monitor compliance requirements applicable to the DP and ensure timely implementation of CDSL circulars.
Coordinate with CDSL on inspections, audits, compliance requirements and operational matters.
Ensure timely submission of all CDSL/SEBI regulatory reports, certificates and returns.
Monitor compliance related to:
- Demat account opening
- KYC and KRA
- BO account maintenance
- BSDA
- Nomination
- Transmission
- Dematerialisation/Rematerialisation
- Pledge/Hypothecation
- Invocation
- Off-market and inter-depository transfers
- Corporate actions
- Account closure and DP surrender
- DIS/eDIS/DDPI processes
- Power of Attorney and authorisations
- Ensure appropriate maker-checker controls across DP operations.
B. Demat Operations Compliance
- Review end-to-end Demat operational processes for regulatory compliance.
- Conduct periodic compliance checks of branches/DP service centres.
- Monitor exceptions, rejected transactions, pending requests and ageing reports.
- Ensure proper maintenance of customer records and statutory documentation.
- Review customer complaints and ensure regulatory timelines are adhered to.
- Monitor unusual transactions and operational exceptions and escalate appropriately.
- Ensure proper reconciliation between DP system, CDSL records, bank/trading systems and other relevant platforms.
C. System & Application Compliance
- Review compliance of Demat-related applications and technology platforms.
- Ensure regulatory requirements are incorporated into system workflows.
- Review system access controls, user roles and privileged access.
- Ensure appropriate Maker-Checker, role-based access control and segregation of duties.
- Review system-generated reports and regulatory MIS.
- Participate in UAT for new Demat features, system changes and regulatory enhancements.
- Ensure proper documentation of system changes, approvals and release management.
- Monitor application logs and system exceptions relevant to DP operations.
D. Cyber Security & IT Audit
- Coordinate Cyber Security Audits, VAPT, IS Audit and System Audit applicable to the DP.
- Coordinate with Information Security, IT and external auditors.
- Ensure timely closure of audit observations and vulnerabilities.
- Monitor VAPT findings
- SAST/DAST findings where applicable
- Vulnerability remediation
- Patch management
- Access control
- Privileged access
- Incident management
- Log monitoring
- Backup and recovery
- Business Continuity Planning
- Disaster Recovery
- Cyber-security controls
- Track critical/high-risk vulnerabilities and ensure defined remediation timelines.
- Review Cyber Incident Response and escalation mechanisms.
- Ensure evidence is maintained for all audit and regulatory requirements.
E. Audit & Regulatory Inspection
Act as the primary coordinator for:
- CDSL Inspection
- SEBI Inspection
- Internal Audit
- Concurrent Audit
- System Audit
- Cyber Security Audit
- Information Security Audit
- Prepare audit checklists and evidence repositories.
- Coordinate responses to audit observations.
- Maintain an Audit Observation Tracker with owner, target date, risk rating and closure status.
- Ensure timely submission of compliance responses.
- Identify recurring observations and implement preventive controls.
F. Risk & Compliance Monitoring
- Conduct periodic compliance risk assessments for Demat operations.
- Identify operational, regulatory, technology and cyber risks.
- Establish appropriate controls and monitoring mechanisms.
- Maintain a Compliance Calendar covering SEBI, CDSL and internal requirements.
- Escalate critical compliance breaches to senior management.
- Support development and periodic review of SOPs, policies and process documents.
G. Training & Awareness
Conduct compliance training for:
- Demat Operations teams
- Branch teams
- Wealth/RM teams
- Technology teams
- Create awareness on CDSL/SEBI regulatory changes.
- Ensure employees understand critical DP controls and customer protection requirements.
Key Regulatory & Technical Knowledge
The candidate should have working knowledge of:
- SEBI regulations applicable to Depository Participants
- CDSL Byelaws & Operating Instructions
- Depository Participant operations
- KYC/KRA requirements
- AML/PMLA requirements
- BSDA
- Nomination
- Transmission
- Pledge & Invocation
- DIS/eDIS/DDPI
- Corporate Actions
- Reconciliation
- Cyber Security Framework
- IT General Controls
- Application Controls
- VAPT
- SAST / DAST
- Vulnerability Management
- Access Management
- Incident Management
- BCP & DR
- Data Security & Privacy
- Audit & Risk Management
Qualifications
Mandatory:
Graduate/Postgraduate in Finance, Commerce, Law, IT or related discipline.
Relevant experience in Depository Participant / Stock Broking / Wealth Management / Capital Markets / Banking.
Preferred Certifications:
NISM Depository Operations certification
NISM Series V-A Mutual Fund Distributors
NISM Securities Operations / related certifications
CISA / CISM / CISSP – preferred for IT/Cyber responsibilities
ISO 27001 certification – preferred
Relevant CDSL/NSDL training/certifications
