Group Head of Financial Crime Compliance

Job Purpose:

• Responsible and accountable to ensure appropriate ABC Group FCC (AML/CTF) Policies and Standards on a Group-wide basis including issuance, maintenance, updating, and dissemination and overseeing implementation.
• Accountable for provision of expert advice on AML/CTF matters Group-wide including follow through and oversight of activities based on advice provided
• Lead and oversight strategic Group-wide projects
• Ownership and accountability of transaction monitoring system and customer due diligence/screening system

Principal Responsibilities, Accountabilities and Deliverables of Role:

• Leadership
• Key responsibilities, accountabilities and deliverables
• Culture and Behaviors

Policy & Standards

• Responsible for Group policies and standards relating to:
• Anti-Money Laundering (AML)
• Countering Terrorism Financing (CTF)

Among others, these will include detailed standards on: 

• Country & Product Restrictions
• Customer Identification
• Customer Due Diligence
• FCC Programme Governance
• Corporate Risk Appetite
• Correspondent Banking
• Trade Controls
• FCC Monitoring & Testing
• FCC Audits
• FCC Regulator Engagement & Inspection Management
• FCC Training
• Know Your Employee
• Outsourcing

Advisory

• Responsible for completing KYC/CDD Questionnaires and participating in KYC calls with Clearing Banks
• Responsible for maintaining Wolfsberg questionnaire and USA PATRIOT Act Certification
• Responsible for maintaining and enhancing the Bank ABC CDD pack
• Accountable for Expert Advisory Support on:
• AML/CTF  Regulations and Policy
• Potential (FCC) Reputation Risk
• Enhanced Due Diligence Results
• Participate and contribute to adhoc priority projects as appropriate
• Ensuring an appropriate AML/CTF training/awareness curriculum is in place and working with relevant stakeholders for effective delivery

Industry Outreach

• Participating in industry user groups for best practice benchmarking purposes
• Establishing and maintaining close working relationships with relevant government Units such as CBB and with counterparts at peer banks
• Conducting regular update briefings of Unit MLROs and COOs
• Issuing regular advisory notices
• Conducting face to face training where appropriate
• Collaborating closely with FC Officer for Sanctions, Financial Intelligence and Systems to ensure that FCC risk spectrum Group-wide is appropriately addressed and risk themes detected are utilized to enhance CDD and other risk standards and processes
• Collaborating closely with Head of Compliance Operations and Systems to ensure that policy changes are adequately communicated and that testing is performed to ensure that policies and standards are implemented and embedded
• Tasking Compliance Monitoring and Testing
• Close collaboration with Group Audit to ensure that key findings are updated into policies and standards.

Job Context (Circumstances & environment surrounding the job):

The effective management of Financial Crime Compliance (FCC) is a high priority for regulators. It is critical to the Banks success this is demonstrable though the procedures, processes and competencies of its people. As such having the right job holder is essential to the Banks overall achievements. It is imperative the jobholder has sufficient seniority alongside their experience and knowledge to influence the most senior executives of the bank.