Responsible for coordinating GFCC program execution within the bank.
- Oversee the development of the firm’s recordation of local GFCC policies and standards and through governance, ensure formal and appropriate review and approval is completed;
- Provide clarification, guidance and risk based solutions to the business on global and local policy interpretation;
- Act as primary point of contact with local regulators and law enforcement authorities for AML/CFT related matters in fulfilment of all AML/CFT regulatory requirements;
- Review local Lines of Business (LOB) procedures (CDD, Wire Transfers, Transaction Monitoring, Investigations, Regulatory reporting, Employee Screening, Record Keeping) and ensure these procedures are in line with local AML policy;
- AML/CFT Prevention through identification and ongoing analysis of risk associated with new products, services, processes, clients and geographies;
- Oversee New Business Initiatives, Products and Services;
- Oversee identification, risk determination and on-boarding/ongoing due diligence of high risk clients;
- Produce, review and act on any AML related management information as part of the firm's global/regional MIS reporting framework;
- Primary oversight on AML monitoring of customers and customer transactions;
- Subject to local laws and regulations, work with Global and Regional GFCC and location Compliance in the investigation of suspicious activity, and resultant reporting obligations;
- Partner with the LOBs and location Compliance Officers to ensure they understand the AML obligations for the business/location they support;
- Assist senior management to enhance and strengthen an AML compliance culture;
- Assist in the development, coordination and implementation of AML training and testing programs for the business;
- Deliver and track progress of both team and in-country AML training and testing programs to closure;
- Manage jointly with the LOBs any internal/external audits & reviews on the local AML Compliance program;
- Develop and maintain appropriate reporting channels and mechanisms to ensure Senior Compliance management are made aware of and appropriately consulted in a timely fashion on significant issues or developments related to the execution of in-country MLRO / AMLO duties, and updated on a periodic basis to the status and effectiveness of in-country AML program;
- Participate in the local management committee meetings and maintain all the AML-related information/documents that are tabled and/or submitted to the committees;
- Review new business initiatives, products and services and address any emerging AML risks;
- Partner with local management committee and respective LOBs to conduct Risk Assessments as required; and
- Provide country LOB senior management with regular updates on key issues and emerging risks.
China Regulation Specific:
- Act as the primary point of escalation from respective employees/LOBs on matters relating to ML/TF and ensure that the information is kept secured and confidential;
- Act as final in-country point of approval/escalation in matters of Suspicious Activity Reporting; and
- Ensure that relevant AML risk issues or local regulatory requirements are addressed or implemented in a timely manner.
- Law / Accounting / Business / Finance Degree
- Minimum 5yrs of relevant AML/Compliance experience preferably with a global financial institution
- Expert on both implementation and advisory in country AML/CFT requirements
- Experience in regulatory investigations, exam and audit management
- Meet the 'Fit and Proper' criteria relating to (a) probity, personal integrity and reputation; or (b) competency and capability
- Strong management and leadership skills, including effective project management abilities;
- A solution driven approach, with exemplary problem solving skills;
- Excellent communication and organizational skills;
- Strong analytical ability and logical thinking;
- Independent decision maker, able to make time-sensitive assessments;
- Ability to work under pressure;
- Sufficient stature, authority and seniority to participate and able to effectively influence decision relating to AML/CFT;
- Knowledgeable and with the expertise to effectively discharge the roles and responsibilities, including being informed of the latest developments in ML/TF techniques and the AML/CFT measures undertaken by the industry; and
- Sound knowledge of local laws and regulations.
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