AVP - CDD Policy Implementation Lead

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The jobholder will have responsibility for driving and managing policy projects and initiatives championed by Regional Head of PIL or Head of GPI on Financial Crime (particularly AML/KYC) policy and to liaise with various stakeholders.

This will include working independently with a mixture of the following responsibilities:

- Supporting PIL team in various locations (and regions if needed)

- Liaising with Financial Crime Compliance (FCC) at all levels as required to manage

- Leading discussions with colleauges/ stakeholders and providing expertise to the initiate and drive forward change request processes in order to make KYC procedures operationally effective & efficient.

- Assisting the relevant Policy Change Management Group (PCMG) meetings & taking responsibility for the preparation work, handling the meetings and managing the implementation of the outcomes

- Providing policy expertise to Production, Management, SMEs, Project Managers and others.

- End to End management on the dedicated policy matters finished with the guidance including for more complicated issues provide support to CDD Policy Implementation team

- Ensure that policy is properly implemented, include training provision, guidance existence, communication through SME News, and policy clarity and highlighting potential risks to stakeholders.

- Building positive relationships with key stakeholders including the Business, Compliance, SMEs and others

- To provide leadership to SMEs, IT Team communicating policy interpretations and implementation

- Collaborate with CDD L&D to support deployment and delivery of internal AML/KYC technical training.

- Maintaining the Policy infrastructure e.g. SharePoint, Governance & Control and other Policy platforms

- Producing Management Information for senior managers in governance the CDD policy implementation process

Principal Accountabilities: Key activities and decision making areas Typical Targets and Measures

Impact on the Business

- Providing policy expertise to drive forward change requests and new policy initiatives to improve operational procedures

- E2E management on dedicated policy projects and initiatives.

- Initiating and negotiating amendments to local KYC standards in conjunction with Heads of Policy and FCC.

- Close cooperation and leading SMEs who filter policy related queries and clarifying queries.

- Taking leadership of policy matters, coordinating with Production and SMEs to resolve issues.

- Manage stakeholder engagement with stakeholders and represent CDD Policy team in official meetings with stakeholders across the bank (FCC, BMO and the Business).

- Preparation of drafts and final versions of guidance materials and coordination of FCC approvals.

- Performing reviews of training materials from policy perspective and working to build strategic learning solutions

- KPI - Efficiency tool in the database measuring the activity of issues resolution.

- Distribute/ communicate regular status reports to target audience.

- Monitor and track the opening/closure of operational risk issues and audit action items.

- Impact analysis compared to real impact assessed post implementation.

- Feedback from key stakeholders.

Customers / Stakeholders

- Supporting the global Policy Implementation team on senior forums (example PCMG, KYN) both in drafting materials as part of planning for such meetings and providing policy expertise.

- Ensuring that policy is properly implemented e.g. training support, guidance development and communications.

- Act as support for GSC/Regional Head of Policy and FCC. Liaise as needed with FCC, SMEs and the Business.

- Regular communications and interactions with senior stakeholders securing their commitment and collaboration and informing them of policy projects and initiatives - Feedback from key stakeholders.

- Training evaluation feedback.

Leadership & Teamwork

- Lead cooperation with SMEs, providing guidance and poliy expertise, clarification of queries and ensuring policy related item is addressed, to positively impact production

- Taking the leadership over the policy projects and initiatives (coordinating between Regional Head of PIL and Head of GPI)

- Develop relationships with other KYC teams, Business Partners and other support teams.

- Ownership of the particular policy projects and initiatives

Operational Effectiveness & Control

- Analyses, challenges and works to improve policy team processes and ways of working to deliver tangible business benefits

- Understand, follow and demonstrate compliance with all relevant internal and external rules, regulations and procedures that apply to the conduct of the business in which you are involved, specifically Internal Controls and any Compliance policy including, inter alia, the Group Compliance policy.

- Maintain Internal Control standards, including the timely implementation of internal and external audit points together with any issues raised by external regulators.

- Proven ability to implement and operationalize new processes/projects.

- Identify process improvements and implement changes to processes where appropriate.

- Ensure completeness of all related e-learning and training.

- Be aware of the Operational Risk scenario associated with your role and act in a manner that takes account of operational risk considerations.

Major Challenges (The challenges inherent in the role that require a continual test of the role holder's abilities)

- The role requires the knowledge broad AML and KYC, andf multiple jurisdiction policies, and also knowledge of internal policy and general regulatory environment to answer all queries from stakeholders.

- To ensure from a policy/technical perspective that CDD processes are implemented in a consistent way across all GBM Banking Middle Office sites in local region (supported by the GSC).

- Working effectively and independently with key stakeholders using strong influencing skills to ensure mutually satisfactory resolution of key issues and the respective responsibilities are understood and discharged.

- Strengthen and add value to the CDD Policy team, transition from reliance on experienced consultants .

- Support the integration with KYCS onshore,other GSC services and Banking Middle Office, rather than standalone model, have the team as an integral part of a continued service.

- Ability to lead policy projects and initiatives, and to work independently as well as part of a virtual team across different jurisdictions and time zones.

- Significant flexibility required to handle shifting priorities on a daily basis including an ability to process large volumes of highly technical data in short time frames and make independent deductions.

Role Context (The environment and operating conditions of the role including the extent of guidance and authority)

The jobholder, as a part of the Client Operations model, will be responsible for ensuring

that the production (from an operational and technical) environment is supported. This will involve providing invaluable support to the CDD Policy Implementation team, KYCS SME, Client Ops stakeholders and NGT IT teams.

Management of Risk (Operational Risk / FIM requirements)

- Maintain awareness of operational risk and minimize the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting

- Cooperate with Risk Management Team in process of implementing the audit reccomendation

- Address high risk issues in a timely manner and ensure systems are secure and resilient, minimizing losses

- Ensure that standards are adopted globally.

- Act strategically about the impact of policy upon operational activities and how this can be mitigated across process and systems such NGT.

- Drives a culture of escalation and compliance through their actions, challenging processes to ensure operational risks are minimized.

Observation of Internal Controls (Compliance Policy / FIM requirements)

- Maintains internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.

- Foster a risk management, compliance culture and implement Group Compliance Policy.

Role Dimensions (e.g. balance sheet size, lending/expenditure limits, size/volume of transactions, budget. in USD- 000)

- KYC due diligence and client identification validation covers most important sites across GBM. The aim of the process is to provide globally standardized service to deliver high-quality client service and meet all regulatory requirements.

Headcount reporting to this role Direct: n/a Indirect: n/a Total: n/a

Knowledge & Experience / Qualifications (For the role - not the role holder. Minimum requirements of the role.)

Knowledge and skills

- Significant level of knowledge about AML/KYC and the regulatory environment in Banking/ FIs

- Client focused approach to work (e.g. internal stakeholders)

- Strong leadership and management ability

- Strong interpersonal skills e.g. communications and influencing, able to build and maintain global relationships

- Ability to influence stakeholders at all level, develop and maintain buy-in to key initiatives

- Outstanding written / verbal communication and presentation skills

- Planning, time management and resource management skills

- Ability to work in a virtual team, that is involved in many projects, which implicates the active attendance in number of different calls/ meetings that need to be managed aside of normal daily tasks

- Fluent in English and other languages (plus)

Essential Qualities and Behaviours

- Positive - can do/ will do- attitude

- Strong capacity to assimilate other stakeholders perspectives and fast learning abilities.

- Pro-active/ Decision making skills

- Flexibility/ self starter

- Ability to assess stakeholder needs to improve customer experience

- Shows resilience under pressure

Experience

- 5 years or more proven experience working in AML/KYC policy or production or compliance role

- Project management and risk management

- People management and leadership

- Working on regional projects and in a global virtual team

Mandeep K Bains
9810939835