AVP - Financial Crime Compliance - BFS

Purpose

The Continuous Assurance program administers a regimen of end-to-end tests on core FCC processes in order to identify Root Causes impacting the effectiveness and sustainability of FCC's control environment thereby providing a high degree of assurance to Risk Owners and regulatory authorities alike that FCC controls receive rigorous oversight and can reliably manage SC's financial crime risk footprint.

The Sanctions Continuous Assurance Manager supports the Financial Crime Compliance (FCC) program by testing adherence to legal and regulatory requirements and Group standards relating to International Sanctions, Terrorist Financing, Anti-Money Laundering, Anti-Bribery and Corruption (ABC), and the Group Operational Risk Framework (ORF). The role is responsible for executing the Continuous Assurance (CA) Sanctions program under the Continuous Assurance arm of the FCC Assurance function thereby meeting regulatory and compliance stakeholder expectations by providing continuous testing of core first line processes.

Strategy

- Ensure that there is adequate support (people, processes, tools, framework, systems) in the department for necessary FCC controls.

- Understand and execute CA strategy in accordance with the CA methodology and Sanctions CA DOI and relevant addendum in day to day operations.

Business

- Lead development and implementation of industry-standard Sanctions Continuous assurance program, including management and coordination of multiple workflows focused on testing Sanctions controls.

- Through communication of CA test results, support stakeholders by informing policy decisions.

- Play an Integral part in working with regulators / Monitor(s) and meet deadlines set by specific inquiries.

- Ensure that key changes (to laws, rules, regulations) are communicated and cascaded to the Sanctions CA team

- Support relevant stakeholders to make decisions based on current and future policies, practices, and trends as informed by CA results.

- Keep track of and provide advice to relevant stakeholders on the interpretation and application of regulatory expectations, laws, best practices and FCC policies.

Processes

- Perform duties of - CA Manager- as mentioned in the CA Methodology and at the direction of the Head of CA.

- Evaluate effectiveness of SC's Sanctions program in mitigating SC's residual risk footprint through an assessment of first line FCC controls with a specific focus on Transaction/Name Screening Controls administered by GBS's Financial Crime Surveillance Unit and FCC Regional Sanctions teams.

- For controls assessed, determine the impact of operational effectiveness ratings and root causes identified.

- Based on control ratings determine corrective actions with process owners, as necessary.

- Monitor completion of corrective actions assigned to control process owners to rectify control deficiencies. Further assess whether control deficiencies and related expectations require internal or external reporting, and are escalated accordingly.

- In the event that internal or external reporting is necessary, ensure parties and activity connected to the sanctions breach have been identified and reported.

- Assess results of supervisory reviews on the work of CA analysts to ensure that outcomes reached are appropriate and to ensure adherence to CA policy and standards.

- Identify, and execute targeted reviews in line with the CA methodology.

- Maintain an expert understanding of international sanctions and terrorist financing regulations to ensure comprehensive CA coverage. Continually monitor the external regulatory and risk environment through various sources to identify financial crime and sanctions risks which may potentially impact the bank and CA process.

- Develop and periodically update CA procedures to address changes in program coverage, process, and/or in response to new risks or industry trends.

- Oversee the effective, timely implementation of CA process, aligned to the CA methodology and TOM, for Sanctions related workstreams.

- Drive best practices and identify and/or provide training opportunities to the CA team.

- Assist Head of Continuous Assurance in handling delegated responsibilities when needed.

- Interface with regulatory supervisors, and Monitor(s) during examinations / onsite reviews, or requested / required meetings.

- Provide data, documentation, and/or walkthroughs requested by Monitor(s), regulators, and Internal Audit and develop validation memos to close findings when necessary.

- Track findings and observations in the reporting and work with control owners to develop action plans.

- Proactively manage time and prioritize tasks to meet testing timelines and regulatory requirements.

People and Talent

- Promote and embed a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm.

- Stimulate an environment where forward planning, prioritization, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm.

- Develops and executes individual and collective training plans to ensure key competencies are sustained across the team.

- Collaborate with training team to help inform the training curriculum to support closing of capability gaps.

- Provide leadership, management, and coaching to direct reports to ensure they are highly engaged and meeting their potential.

- Ensure staff in the team have clearly articulated and well understood roles and responsibilities through meaningful and accurate job descriptions.

- Ensure the Sanction CA team is adequately resourced and sufficiently independent to perform duties objectively.

Risk Management

- Ensure a thorough understanding of the risk and control environment in area of responsibility.

- Make recommendations (and/or implement) to relevant stakeholders on possible risk management responses to identified risks and/or findings of concerns from testing.

- Inform senior management and relevant regulators of serious regulatory breaches (or where risk tolerances have been breached) and ensure that actions are taken quickly to remediate and/or activities are ceased.

- Understand end user functionality of transaction screening, name screening, and other support systems.

Governance

- Develop and manage appropriate FCC CA DOIs.

- Collaborate with Operational Risk counterparts to ensure residual risk ratings accurately reflect risks identified through Control Sample Testing (CSTs).

- Partner with Operational Risk in mapping CSTs (or proposing new CSTS) to control failure points.

- Prepare metrics reporting designed to highlight FCC risks and root causes impacting control stability.

- Be accountable for identification and escalation of potential risks and issues to senior management.

- Propose control improvements, enhancements and/or highlight opportunities for increased efficiency, where appropriate.

- Track significant Sanctions related concerns arising from FCC metrics, Assurance activities, audit reviews and regulatory inspections.

- Deliver - effective governance; challenge fellow executives effectively; and work with any local regulators in an open and cooperative manner.

- Attend relevant leadership meetings.

- Prepare and cascade lessons learned from audit findings, FCC assurance activities and specific investigations that may have implications on CA workflows.

- Awareness and understanding of the regulatory framework in which the firm operates, and the regulatory requirements and expectations relevant to the role.

Regulatory & Business conduct

- Support relevant stakeholders to respond to regulatory questions, as required

- Display exemplary conduct and live by the Group's Values and Code of Conduct.

- Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.

- Lead the FCC CA function to achieve the outcomes set out in the Bank's Conduct Principles

- Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.

Key Stakeholders

- Support close interaction with 1st line stakeholders and CA.

- Support close interaction with Operational Risk and CA.

- Support close interaction with FCSU Quality Assurance and CA.

- Support the close interaction between Continuous Assurance and Thematic Assurance.

Other Responsibilities

- Embed Here for good and Group's brand and values in FCC CA function globally.

- Embed the Group's values and code of conduct to ensure that adherence with the highest standards of ethics, and compliance with relevant policies, processes and regulations among employees form part of the culture.

- Perform other responsibilities assigned under Group, Country, Business or Functional policies and procedures.

COMPETENCIES:

Accountability, Scope and Leadership

- The role draws from extensive experience in interpreting Sanctions risk and relevant regulatory reporting requirements to inform CA testing and reporting strategy.

- Role is required to have a strong conceptual understanding of the activities undertaken across FCC.

- Delivers on key objectives by translating complexities between CA/operational process, product, and/or regulatory requirements into a cogent, workable solution.

Knowledge and Expertise

- Is able to articulate the specific business products or support services; is able to describe the processes and controls that underpin them, along with the key risk points

- Demonstrates in depth knowledge of the Continuous Assurance Methodology and can accurately describe the following principles:

(1) Assurance's placement within the three lines of defence from an FCC perspective.

(2) Fundamental Differences between Continuous Assurance and Deep Dive Thematic Assurance.

(3) Sampling strategies to minimize sampling risk and ensure representative sampling.

(4) Approaches to performance of Root cause Analyses at both the Case and Control level and Assessment of the Likelihood and Impact of Control Failure.

(5) Regulatory Approaches to conducting a BSA/AML Audit (e.g.. FFIEC Guidance).

- Demonstrates strong understanding of Compliance regulations, industry best practices, knowledge of global procedures and policies, with deep subject matter expertise in one or more AML, Sanctions, CDD, Anti Bribery. Adept in understanding and able to coach downstream impact of risk

Problem Solving, Complexity and Influence

- Makes sound decisions; bases decisions on fact rather than emotion; analyses problems skilfully; uses logic to reach solutions; shows an "investigative" mind-set

- Demonstrates confidence to defend decisions while maintaining effective working relationships. Has built respect with 2nd line partners through contribution of Assurance assessments to the function. Adept in engagement with regulators.

- Communicates clearly and concisely (written and verbal) demonstrates engaged listening skills; able to maintain composure in a stressed situation; reads non verbal communication queues. Is able to communicate difficult messages without creating conflict or destroying trust. Clearly influences outcomes.

- Has experience in management/supervisory responsibility. Management capability demonstrated through coaching, developing, supervising or influencing of others; experience in workflow management