Deputy Anti-Money Laundering Manager (Iraqi nationals only)-2400003628

The Role Responsibilities

This role is only open for Iraqi nationals

The role of Deputy AML Manager is to support the Country Head of FCC in the execution of their accountabilities in so far as they relate to CFCC related processes and will support the Country Head of FCC in;

Strategy

• Assist in the implementation the vision, strategy, and direction for CFCC, consistent with the regions vision and strategy for the CFCC function and in support of the Bank’s strategic direction and growth aspirations.
• Promote the culture and practice of compliance with CFCC standards (including conducting business within regulatory requirements, and to high ethical standards) within the Bank and embed a Here for good culture and the Group Code of Conduct.
• Input to Country Business operating model design of relevant Compliance, FCC, Conduct and business processes.

Business

• Build and maintain an effective and constructive relationship with all key business and functional stakeholders that is based on trust, capability and integrity, providing timely, responsive and quality CFCC related advice and guidance to enable the business and functions to meet/ achieve their strategic tactical objectives.
• Provide CFCC advice, analysis (and challenge when appropriate) including product design, new business initiatives, bespoke projects, remedial activities (including nature, scale and rigour of past business reviews), and transactional advice.
• Provide robust challenge to relevant stakeholders where activities are outside risk tolerance/ appetite, escalating as necessary, until appropriate oversight and ownership is achieved including actions and plans to address any remedial action needed to come back within risk tolerance/ appetite.
• Work closely with the business and its operational teams to provide timely advice to ensure compliance with all relevant laws and regulations and support the transition to pro-active and pre-emptive CFCC risk mitigation.
• Support the resolution of competing requirements between regulations specific to businesses (i.e. between AML regulations and data privacy/bank secrecy or information security regulations.)
• Develop a good working relationship with GBS FCSU and participate in regular Service Delivery Meetings with them.
• Support ad hoc CFCC training initiatives where appropriate
• Regular and diarised catch up with all key business stakeholders on regular basis or for specific adhoc/arising business cases/issues.
• Work closely with respective business compliance teams to ensure products and transactions are appropriately designed and implemented as per the global standards and local requirements.
• Arrange to support waivers/dispensations that might be needed on a risk based approach in return to local requirements implementation and work with the business in seeking regulatory approvals demanded as required (ie CIB Tools)
• Arrange to review and set the local country addendums, where needed, vs the group standards and policies.
• Attend business/functions risk, complaints, clients experience, Data Governance forums and any other committees/forums that would require CFCC presence either as a member or primary invitee.

Processes

• Develop and maintain effective policies/processes/DOIs (including training, advice and support) to address conduct, financial crime and compliance risks, aligning with relevant regulatory requirements.
• Provide governance and oversight over the implementation of CFCC related policies and procedures (to enable compliance with such policies and procedures).
• Provide support and challenge to the management to ensure that they establish and monitor appropriate processes for compliance with CFCC policies, procedures and standards (including meeting regulatory obligations and maintaining high standards of conduct).
• Second line challenge to processes owned by the first line, including (but not limited to) specific Risk Framework Owner oversight of Complaint Handling, Client Off-Boarding, Know Your Distributors, Loan Sell-down, Enterprise Approprateness, Regulatory On-Boarding, CDD, AML Sureveillance, and Customer Screening along with the other risk sub types mapped to CFCC as second line.
• Work with the Country Head of FCC to manage and develop the relationship with the regulators in accordance with the Regulatory Relationship Plan and ensure regular updates are shared with relevant governance forum.
• Help ensure the Bank is properly prepared for regulatory inspections and coordinating responses with the business in line with the Group Regulatory Guidance Note.
• Proactively monitor regulatory developments to manage the regulatory impact of complex regulatory matters on the Bank's business and its operations
• In the event of serious regulatory breaches, or where risk tolerances have been breached, assist in critical workstreams in order to ensure senior management and relevant regulators are informed and that actions are taken quickly to remediate and/or activities are ceased.
• Track significant issues arising from CFCC metrics, Assurance activities, Audit reviews and regulatory inspections, providing validation of issue closure where necessary.
• Day to day management and oversight of AML Investigations work that arises from Transaction Monitoring alerts (automated & manual alerts/IRs, OTCs and IXs), including alerts generated from Trade Surveillance, Transaction Screening and credit card monitoring, additionally to MIs generated and shared by Central Compliance, Businesses Conduct Registers, RRMI maintenance and reviews.
• Support complex investigations to include Group or Regional-level i3 cases.
• Processing and concluding cases allocated in a timely manner within agreed TATs whilst maintaining Quality Control/Quality Assurance results in line with Group and local expectations.
• Ensure timely initiation of follow up actions including heightened monitoring, CDD review and list additions.
• Local Policy(s) monitoring and reviews.
• Compliance Risk Assessment as per Group Compliance Risk Assessment Methodology and handle any further data driven reviews and track the CRA action plans with updated featured to CRC and work with the Regional Compliance Assurance Team on the Compliance Assurance plan and review for the country.
• Maintenance of the Compliance Obligations Register and ensure controls driven from Group Standards for Managing Legal and Regulatory Obligations by Compliance are effectively implemented and produce the required Residual Risk Assessment for CFCC Head approvals.

People & Talent

• Build the appropriate culture and values. Work in collaboration with risk and control partners.
• Promote and embed a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm.
• Support an environment where forward planning, prioritisation, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm.
• Assist in the migration of skill, knowledge, best practice and lesson learned across the network between CFCC colleagues especially in relation to legal/regulatory risks and compliance with relevant regulations and internal policies/standards.
• Drive a comprehensive Training Plan for the country & ensure relevant stakeholders are informed of key changes and updates on key CFCC policies and procedures.

Risk Management

• In collaboration with the CFCC team, effectively manage regulatory issues that have a significant impact on the SCB including but not limited to conflicts of interest, cross–border and onshore/offshore transactional support and control.
• support the Head of FCC in the programmes for conduct, financial crime and compliance monitoring, surveillance and/or assurance
• Ensure proactive and timely identification, assessment, advice and dissemination of evolving regulatory changes/practices and associated risks, and proactive engagement in regulatory reform.