Executive Director, FCC, Policy, Client Risk Framework
- Define and maintain key standards to build controls for financial crime risk into client and product processes, including:
- Group Customer Due Diligence (CDD) procedures and related control standards;
- CIB/CB Segment specific addenda and related control standards;
- Product Due Diligence procedures
- Refine and fine-tune the Client Risk Assessment methodology (not modelling which FCIIU is responsible for).
- Final point of escalation within FCC as to the interpretation of Group CDD procedures and related controls.
- Establish governance over the process for dispensation from Group and Business CDD procedures.
- Ensure that the Group and Business CDD procedures remain up-to-date and in compliance with laws, regulations and industry best practice through the maintenance of an obligation register.
- Work with CRA to refine and fine-tune the Client Risk Assessment methodology (as indicated above) and assume ongoing ownership in BAU.
- Lead FCC input to the OneBank CDD programme from CIB/CB and Product Due Diligence perspective.
- Key interface with Group technical experts on Sanctions, Bribery and overall AML to incorporate requirements into CDD standards.
- Support the wider Compliance function to embed controls for other compliance risks in client processes.
Key Roles and Responsibilities
* Analyse comprehensive impact of financial crime related regulatory matters on the relevants business area and its operations.
* Ensure that key changes to laws, rules, regulations relevant to CDD in relation to AML/CTF are communicated and cascaded, in coordination with group communications.
* Support relevant stakeholders to make decisions based on current and possible future policies, practices, and trends.
* Keep track of and provide advice to relevant stakeholders on the interpretation and application of regulatory expectations, laws, best practices and policies related to FCC.
People and Talent
* Provide leadership, management and coaching to direct reports to ensure they are highly engaged and performing to their potential.
* 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, prioritisation, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm.
* Ensure Department is adequately resourced and staffed by an appropriate number of competent staff sufficiently independent to perform duties objectively, to support sustainable business growth and address financial crime risks.
* Ensure staff in Department have clearly articulated and well understood roles and responsibilities through meaningful and accurate job descriptions.
* Maintain oversight of risk mitigating action plans.
* Understand technical aspects of systems relevant to CDD, Client Risk Assessments, Name and Transaction Screening, AML Monitoring and Case Management.
* Review and assess existing system and controls relevant to FCC to ascertain operational performance and effectiveness.
* Align/support with the alignment of relevant systems and controls to industry best practice and close out any compliance gaps.
* Apply Group and FCC policies and processes (AML surveillance, client screening, risk assessment) to manage risks.
* 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.
* Anticipate horizon risks in the area of financial crime that may have a significant impact on the Group and develop effective strategies to mitigate such horizon risks.
* Develop and/or implement risk management frameworks (e.g. ORF, GRA) including methodology, governance / process, analysis and action planning.
* Advise relevant stakeholders on outcomes of AML/Sanctions/ABC risks identification and assessment methodologies.
* Attend relevant leadership meetings.
* Provide and support senior oversight of FCC region/country/function.
* In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure senior management and relevant regulators are informed and that actions are taken quickly to remediate and/or activities are ceased.
* Prepare and cascade lessons learned from audit findings, FCC assurance activities and specific investigations.
* Propose control improvements, enhancements and simplifications where appropriate.
* Implement quality assurance standards and workflows for the FCC Assurance function.
* Be accountable for identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.
* Define metrics and/or key risk indicators (KRI) especially for AML, Sanctions and ABC.
* Analyse and interpret data to produce reports that help the bank identify and manage emerging areas of risk / vulnerability and thus drive remediation action within the FCC function.
Regulatory & Business conduct
* 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, across Standard Chartered Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.
* Lead the Client Control Standards Team to achieve the outcomes set out in the Bank's Conduct Principles: Fair Outcomes for Clients; Effective Operation of Financial Markets; Financial Crime Prevention; The Right Environment.
* Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.
* Support relevant stakeholders to respond to regulatory questions.
* Infrastructure to support implementation of Obligations Register.
* Embed 'Here for good and Group's brand and values in all Group Businesses.
* Perform other responsibilities assigned under Group, Country, Business or Functional policies and procedures.
Qualifications and Skills
* Strong knowledge of the businesses, markets and operations of a global financial institution
* Strong knowledge of client and product due diligence policies, procedures and processes through which financial crime risks are addressed
* Sound judgement and anticipation
* Ability and willingness to take decisions and manage a team
* Strong integrity, independence and resilience
* Ability to establish strong relationships with external and internal stakeholders
Take the Lead
Universal Technical Competencies
Compliance Technical Competencies
Compliance Policies and Standards
Compliance Risk Assessment