Senior Manager, Sanctions Governance

Key Accountabilities

• Perform bank-wide risk assessment to identify the Bank’s exposure related to the risk of Trade Based Money Laundering (TBML) and breach of local/international Sanctions, including but not limited to the sanctions imposed by UN, OFAC, UK-HMT, EU, and Qatar NCTC etc.
• In view of the bank’s exposure to the risk of TBML and breach of local/international Sanctions, develop appropriate risk strategies by enhancing the bank’s controls related to TBML and Sanctions e.g. the development of appropriate Policies, Procedures, Systems and Controls.
• Work collaboratively with the team to provide timely, accurate and sound advice to business in the area of Sanctions and TBML, including advice related to customer payments and bank transactions in the context of local/international Sanctions.
• Manage ongoing customer and payment screening activity conducted by Sanctions Governance team, ensuring that appropriate and swift actions are taken in relation to the payments stopped by the bank’s filters.
• Manage ongoing TBML monitoring activity conducted by Sanctions Governance team to ensure that the underlying TBML risk is appropriately mitigated,
• Participate in the development of TBML automated scenarios and manual reports and conduct periodic effectiveness assessment of TBML scenarios.
• Ensure timely and accurate processing of name search requests received from local regulators and law enforcement, and taking the necessary actions to block/freeze accounts/assets of designated persons in line with QCB regulations.
• Maintain a robust list management programme to ensure that the bank and its customers do not do business with sanctioned parties or deal in banned materials etc. Actively manage black- and white lists ingested in the bank’s screening systems.

Other Accountabilities

• Represent the bank in all interactions with correspondent banks on Compliance, AML/CFT and Sanctions related matters. Receive and respond to correspondent banks’ inquiries in a timely and accurate manner. Conduct periodic AML/CFT and Sanctions assessment of “vostro” correspondent banking accounts and respective third-party financial institutions.
• Analyse data, prepare and present reports related to Sanctions and Adverse Media screening, risk assessments, and monitoring of Sanctions related issues and escalations to senior management and correspondent banks.
• Assess and provide advice on new business initiatives and new products from Sanctions perspective.
• Partner with stakeholders within Compliance, Operations, IT and business units, as applicable, to ensure potential risks are appropriately vetted and addressed. Identify and escalate to the Head of AML/CFT and Sanctions the material risks and significant instances of not adherence to the bank policies and procedures by the accountable front line units are appropriately reported.
• Oversee adherence to procedures and processes, to ensure compliance with the relevant policies and procedures by ensuring that front line units meet required standards. Promoting global consistency of Sanctions compliance practices and policies – within the business lines.
• Interact with senior management to raise awareness of Sanctions trends, emerging issues, remedial actions or enhancements to the Sanctions Compliance Program. Assessing the impact of issues/violations (legal/regulatory, policy, reputational, etc.), streamline control gaps and help management to define disciplinary and corrective actions, as appropriate.
• Work collaboratively with the team to provide advice to business with respect to applicability of policies and implementation of the economic sanctions program and regulatory changes.