Principal Purpose of the Job
- To support the Bank’s MLRO their duties in maintaining an effective and efficient financial crime prevention framework.
- Maintaining an effective sanctions compliance framework in line with the UK, US, EU and UN regulatory expectations.
- FCP Assurance and Advisory related tasks, which includes: High Risk Case reviews; EDD Reports; FCP Escalations for guidance and approval; risk amendments requests on system; Exceptions and Waivers review; Client off boarding; PEP Risk assessments; and update and manage relevant logs (e.g. Sanctions, PEPs, Exceptions/Waivers and etc.)
- Draft, review and update FCP related policies, procedures and manuals;
- Undertake comprehensive risk assessments which are part of the FCP monitoring plan;
- Undertake QA reviews which are part of the FCP monitoring plan;
- Actively manage the FCP advisory inbox, along with relevant Trackers and logs; and
- Assist the line manager and the peers in the team as and when required.
Main Responsibilities & Accountabilities
Report directly to the MLRO of the Bank, supporting in the oversight and management of the Bank’s efforts in preventing and detecting financial crime risks;
To provide financial crime prevention (FCP) advisory across the Bank with an emphasis on Sanctions, ABC, TF, Fraud prevention and CDD in accordance with relevant laws, regulations and internal policies;
Undertake thorough assessment of CDD files (especially High risk and EDD reports), and subsequently provide comments, rationale and obtain MLROs approval;
Undertake thorough assessment of financial crime risks as part of the customer due diligence process;
Proactively support the team with comprehensive risk assessments including EWRA, Country Risk, Product Risk, Client Risk, Third Party Risk, Bribery & Corruption Risk, Fraud Risk and etc.
Review Gifts and Hospitality requests, and provide adequate assessment;
Manage daily responsibilities of the Financial Crime advisory function, provide support, guidance and training to the relevant staff across the bank, and maintain an effective management reporting line;
Maintain an awareness of current Financial Crime regulations and legislation and ensure that changes are reflected in the following Bank’s policies, procedures and appendices: Anti-Money Laundering (AML), Customer Due Diligence (CDD), PEP, Sanctions, Fraud, off boarding, Anti-Bribery & Corruption, Trade Finance, Gifts & Hospitality, Sanctions, Country Risk Assessment, and Customer Risk Rating Methodology;
Undertake systems functionality and framework testing for CDD, Trade Finance, Fraud, Sanctions and etc.
Perform ongoing reviews as determined by the FCP monitoring plan;
Ensure completion of quarterly CDD and Trade Finance QA reviews;
Where applicable, undertake annual reviews and assessments which are part of the FCP monitoring plan;
Support delivery of the Bank-wide Financial Crime Risk Assessments;
Ensure ‘group-wide’ policies and procedures are implemented as and where applicable;
Assist Head Office with Sanctions Risk Assessments and other Sanctions related matters;
Support the Transaction Monitoring team with the clearing of STORMS alerts in case of high volumes or absences;
Attend KYC due diligence calls/meetings with counterparties and generate call reports;
Re-open, suspend and reactivate clients on relevant systems;
Maintain personal and professional development and training in order to discharge responsibilities;
Design FCP related course materials and ensure staff within the Bank receive adequate training in: AML, CTF, Sanctions compliance, Fraud identification and detection, ABC, new starter’s financial crime induction (monthly) and other financial crime related matters.;
Review and approve Trade Finance escalations;
Support and assist the MLRO with relevant reports, such as MLRO, MIP, EWRA, HO, FCA and other relevant reports; and
Ensure any other FCP related tasks assigned by the direct line manager are completed in a timely manner.
Skills and Experience Required:
Strong technical financial crime and regulatory and legislative knowledge, including Money Laundering, Terrorist Financing, Sanctions, Fraud, Bribery & Corruption, Trade Finance, Facilitation of Tax Evasion and Modern Slavery;
Strong Trade Finance, Sanctions, Fraud prevention and ABC advisory experience, preferably gained from acting as a SME in a bank/financial institution;
Strong Knowledge and previous experience in Trade Based Money Laundering is a must;
Practical knowledge and experience of the following: JMLSG, MLR 2017, POCA 2002, EUMLD, The Bribery Act 2010, International Sanctions;
Exceptional attention to detail and good application of the risk-based approach;
Experience of sanctions payment screening and transaction monitoring systems;
Experience in financial crime compliance or audit roles with demonstrable career development;
Track record of performing in a wholesale banking environment with exposure to high risk scenarios;
Good knowledge of the relevant FCA rules pertaining to sanctions and financial crime systems and controls and UK Money Laundering Regulations;
Strong second line advisory experience within the areas of financial crime compliance specifically in Trade Finance, Sanctions and Fraud prevention and detection;
Ability to undertake research and analysis and exercise sound judgement;
Ability to balance risk and practicality to determine appropriate action and solutions;
A proactive and effective problem solver with good communication skills;
Excellent stakeholder management experience with a focus on interaction with the Business and an ability to balance risk management considerations and commercial factors;
Ability to be proactive and think outside of the box in terms of introducing and enhancing control process, reporting, and FCP oversight;
Proven team player who can fit comfortably into new environments, work diligently at all levels with meticulous preparation, attention to detail and commitment, and a track record of delivering results;
Previous payment, banking, law enforcement, or regulatory experience;
Proven experience in entity types such as, Funds, SPVs, Trusts, Foundations, Charities and LLPs;
An understanding of complex ownership structures and experience of the breadth of Financial Crime
requirements for a range of corporate and FI entities both in the UK and overseas is essential.
Other Factors:
Bachelor's Degree or higher education (preferred).
Diploma or higher education in Financial Crime Prevention from ICA, ACAMs or equivalent is a must.
Certification and/or a diploma in Sanctions compliance is a must.
The job holder may be asked from time-to-time to provide assistance on wider compliance issues;
