BNP Paribas is a leading bank in Europe with an international reach. It has a presence in 74 countries, with more than 192,000 employees, including more than 146,000 in Europe. The Group has key positions in its three main activities: Domestic Markets and International Financial Services (whose retail-banking networks and financial services are covered by Retail Banking & Services) and Corporate & Institutional Banking, which serves two client franchises: corporate clients and institutional investors. The Group helps all its clients (individuals, community associations, entrepreneurs, SMEs, corporates and institutional clients) to realize their projects through solutions spanning financing, investment, savings and protection insurance. In Europe, the Group has four domestic markets (Belgium, France, Italy and Luxembourg) and BNP Paribas Personal Finance is the leader in consumer lending. BNP Paribas is rolling out its integrated retail-banking model in Mediterranean countries, in Turkey, in Eastern Europe and a large network in the western part of the United States. In its Corporate & Institutional Banking and International Financial Services activities, BNP Paribas also enjoys top positions in Europe, a strong presence in the Americas as well as a solid and fast-growing business in Asia-Pacific.
Compliance Advisory – Compliance Advisory team is responsible for:
Defining compliance transversal norms, global charters, policies and procedures,
Formalizing decision making processes,
Defining the framework under which the procedures of the Compliance are established and implemented within the Function,
Deploying and overseeing the control framework for banking and tax laws with extra-territorial reach.
The Volcker Office is a Compliance global team which was created on June 1st, 2015 covering two regulatory streams: Client Fiscal Compliance (AEOI, FATCA, and QI) and Structural Banking Reform (CFTC Swap Dealer, French Banking Law, and Volcker Rule). Its key missions are to:
Organize and supervise the attestation and certification processes at Group Level with an objective of timeliness, consistency and efficiency across Poles and Métiers
Own the Group generic control plan and sponsors the independent testing program, in partnership with IG-Audit and Compliance review teams, to ensure the continuous effectiveness of the Volcker-FBL Internal Compliance Program (ICP) at Group level. Ensures the proper governance around the controls deployment
Report and escalate to senior management any breach or deviation uncovered during the ICP execution
Business Overview Cont'd:
Maintain the set of Group policies and procedures related to the regulations in scope
Provide advisory to Métiers and Poles in connection with Risk, Legal and Compliance teams
Set training standards, design and maintain awareness of generic e-learning modules
Ensure proper Group documentation and record-keeping
The Volcker Office partners with and coordinates with Functions (Audit-IG, Legal, Risk, Compliance, Finance, HR) and relies on a network of active Single Points of Contacts at each Métier/Function level.
On an annual basis, the Volcker Office will report to Group instances on its activities, findings and recommendations.
For the following regulations which are primarily within the scope of responsibilities of the Global Banking and Fiscal Regulations team (formerly known as the Volcker Office), i.e. the Structural Banking Reforms (Volcker Rule, French Banking Law and other new regulations that may emerge in this area) and the Tax Avoidance Prevention laws (FATCA, AEOI) and possibly other new regulations that may emerge in this area. The scope of responsibilities also includes additional duties to cover CFTC Swap Dealer governance to support CFTC swap rules and regulations adopted under Title VII of Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank Act"). The Senior Officer is in charge of the following for the U.S.:
Bring relevant expertise and provide advisory services to the Métiers and Group Control Functions on the above regulations
Steer the deployment of the BNPP second-level Internal Control Plans (ICP) related to the regulations listed above and control the effectiveness of their deployment on the ground, as a Level 2 control group
Adapt Group procedures and guidelines to reflect any change in regulations and adapt the ICP framework accordingly
Build and deploy Level 2 permanent control capabilities, coordinate Compliance Review Team efforts in their testing of first and second level controls related to in-scope regulations; steer the risk assessment at Group and Métier Levels in coordination with relevant internal and external parties as the case may be
Ensure that the ICP and risk assessment are closely monitored, acted upon on an ongoing basis, that risk areas are properly identified in order to adapt the ICP accordingly, and propose the necessary actions to relevant teams and management
Execute on-site controls when appropriate and in conjunction with Métiers, other Level 2 and Level 3 control teams and outside firms if needed, and upon request of regional management
Coordinate the Independent Testing annual run with relevant internal and external parties as the case may be
Design and deploy the Group certification process for all Métiers and entities as per Group rules; communicate it to senior managers and steer its effective annual implementation
Ensure the deployment of a robust training plan at Group level and define standards in conjunction with HR partners. Ensure the effective deployment of an appropriate training plan at Métiers level. Contribute to the organization of training events locally and globally
Contribute to the design, deployment and run documentation repository tools to facilitate audits and controls by level 3 control teams (Inspection Générale) and external regulators
Contribute to the response to external regulators, both on a regular basis as per legal requirements, and upon request
Contribute to any internal reports and regional governance required within the Group (e.g. CIRCC, Comex, Management Committees and Board meetings)
On a case by case basis, provide Advisory services to the Business for specific new transactions or activities for which Legal, Risk and/or Compliance teams are unable to arrive at a definitive position and require a second opinion
Any other task which may be required under the final definition of the team Mission Statement.
Contribute to the design and deployment of a recordkeeping strategy at Group level, as well as the definition of data integrity and safekeeping rules
Participate in the Métiers governance and cascade of review meetings if agreed with the Métiers (ex: sub-ICC participation within CIB)
Sponsored and coordinated processes shall be delivered in a timely manner. Risks of execution shall be escalated promptly to management.
Minimum Required Qualifications:
Bachelor Degree or Juris Doctorate degree with relevant experience
5+ years of experience working with Volcker compliance and banking regulations with a Bank or Financial Institution.
2 years of experience working with Volcker at a Bank or Financial Institution.
Working knowledge of U.S. and International G10 regulations in the area of structural bank reforms and OTC derivatives; ability to provide oral and written advice on the go.
Strong capabilities to spot and anticipate issues when reviewing the Risk Assessment and Internal Control plans.
Strong organizational and project management skills (documentation, issue tracking, effective coordination). Ability to frame and document complex issues in order to prepare for senior managers decisions.
Strong interpersonal skills in order to foster collaboration within the team and with key partners: Legal, other Compliance teams and departments, Risk-GRM, Métiers, and other control functions.
Strong communication skills with the ability to communicate clearly and succinctly on complex and possibly sensitive topics to all levels of senior managers in the BNP Paribas regional and central organization.
Keen sensitivity to risks; rigor and independence in addressing those risks
Strong work ethic and Compliance mindset; integrity and an ability to work autonomously
7+ years of relevant experience in a Volcker office position or similar role in Compliance/Legal or Risk departments covering above referenced regulations.