Reporting to the Head of Financial Crime Programme, the role entails providing Fraud and Financial Crime related advice relating to the AML/CTF, Sanctions, ABC, Anti- Tax Evasion Facilitation and Fraud Risk Pillars (collectively known as Compliance Risk Pillars). Working closely with the first line of defence Business Areas, Compliance teams who support this activity as well as other units in the first line of defence.
Good working knowledge of providing support on Fraud and Financial Crime issues as well as a thorough understanding of best practice and risk mitigation, and the practical application of this advice in a global context. The requirement of the role will be to lead and support the strategic development of the Financial Crime Programme.
Reporting to the Head of Financial Crime Programme, the role entails providing Fraud and Financial Crime related advice relating to the AML/CTF, Sanctions, ABC, Anti- Tax Evasion Facilitation and Fraud Risk Pillars (collectively known as Compliance Risk Pillars). Working closely with the first line of defence Business Areas, Compliance teams who support this activity as well as other units in the first line of defence. Good working knowledge of providing support on Fraud and Financial Crime issues as well as a thorough understanding of best practice and risk mitigation, and the practical application of this advice in a global context. The requirement of the role will be to lead and support the strategic development of the Financial Crime Programme.
The key responsibilities of the role will include:
Define risk appetite statements for all Compliance Risk Pillars (where appropriate) e.g. including but not limited to 'excluded and restricted relationships from an AML/CTF perspective'.
Lead and take an active role in developing and maintaining the Financial Crime Programme function by advising on the continual update and enhancement of relevant policies and procedures and local addenda in line with the regulatory obligations or relevant risk events.
Oversight of appropriate on-boarding and periodic risk-based Customer Due Diligence (CDD) including relevant guidance issued by the FCA and JMLSG.
Ensuring the implementation of legal obligations register and application of robust operational controls.
Ensuring the oversight and continued update of MI relating to Fraud and Financial Crime processes
Oversight of appropriate policies, procedures, systems and controls to mitigate Fraud & Financial crime risks.
Take reasonable steps to establish and maintain adequate arrangements for awareness and training in Financial Crime matters (in conjunction with other staff). The role will require delivery of Fraud & Financial Crime Training to all staff, including targeted training to the second line of defence and/or first line of defence where appropriate.
Day to day issues affecting a financial crime team of a global investment bank; including governance, policy, risk assessment, procedures, operations and reporting, external reporting and feedback into the overall financial crime risk management process.
Source, review, disseminate and act on national and international findings as required by FCA and/or the law enforcement authorities.
Ensuring Governance arrangements with regards to relationships of any outsourced AML/CTF activities.
Delivery of mandatory external reporting e.g. Annual MLRO report, REP-CRIM, Annual Report of Blocked Property.
Successful applicant expected to be conversant in all Compliance Risk Pillars however will lead/ act as the SME for the AML/CTF pillar.
Key activities and key competencies
Provide Fraud & Financial Crime related advice and support on a proactive and reactive basis in respect of the specified entities and other entities as required, working closely with the business line Compliance teams who support this activity and the Client Lifecycle Management Team.
Liaise and coordinate with other compliance staff in offices to facilitate harmonisation of global standards and policies across the group and maximise flow of useful information.
Be a key member of the second line of defence team with regards to financial crime and fraud prevention and provide support to the Head of Financial Crime – London branch.
Knowledge of UK regulatory and legislative requirements and appreciation and awareness of industry best practise and standards. Knowledge of German UK regulatory and legislative requirements is desirable.
Ability to clearly identify and articulate risk appetite in order to determine mitigating factors and potential controls to mitigate and manage residual risk.
Production of an AML/CTF, Sanctions and Fraud risk assessment – for the organisation as a whole, its businesses, the jurisdictions, customers, products and delivery channels.
Ability to articulate impact of changes to policies, standards, addenda and relevant procedures including ability to provide training on relevant changes.
Strong working knowledge, understanding and practical aspects of an effective financial crime risk management framework.
When required, maintain involvement in industry working parties, groups and external forums on AML and Sanctions to keep practice in line with good industry practice in this area.
Provide AML and other financial crime related input on group and general issues as required and promote effective financial crime compliance. This will include supporting more junior or less experienced members of staff as well as communicating upcoming changes to key business units and acting as a subject matter expert for all Compliance Risk Pillars in order to support all advisory enquiries.
It would be beneficial to have practical knowledge of Trade Finance and/or Investment Banking products.
Contribute to the bank's EWRA (Enterprise wide risk assessment) and any other projects as required.
Oversight of Compliance Risk Pillars, and Trade Finance advisory. When required, assist Group representatives and representatives from the authorities and regulator during audits/reviews, etc.
Whilst employed, you will conduct yourself in accordance with the FCA's Conduct Rules at all times. These rules are:
You must act with Integrity
You must act with due skill, care and diligence
You must be open and cooperative with the FCA, the PRA and other regulators
You must pay due regard to the interests of customers and treat them fairly
You must observe proper standards of market conduct
Experience in Compliance or a relevant field, broad second line of defence Financial Crime experience desired with a strong focus on advisory services.
Detailed knowledge and understanding of local and international regulatory frameworks.
Ability to lead teams in a manner that encourages them to work efficiently with an attention to detail in their general everyday activities.
Exceptional oral, written and interpersonal communication skills with the ability to communicate complex information accurately, clearly and quickly to all levels. German language skills are an asset.
Knowledge of corporate company structures and weaknesses from AML perspective.
4-7 years' experience of well-rounded investment banking knowledge.
1-2 years' supervisory experience.
Familiarity in dealing with law enforcement and regulators, an existing network would be an asset.
Project management skills and experience.
ACAMS certified or equivalent BSA/AML certification preferred.
Vocational training, university degree or similar, preferably in Banking, or Law Specialist or Enforcement knowledge (work experience, further qualification).
Internal Number: 6380000
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