Strategy
• Ensure that there is adequate support (people, processes, tools, frameworks, systems) in the ASA region for necessary FCC controls.
• To manage within tolerance the risk of financial, regulatory or reputational loss to SCB by assisting the business and support units to meet the Sanctions requirements of the Group and all applicable local laws, rules and regulations concerning Sanctions.
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• 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) are communicated and cascaded (in region/country), 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.
Processes
• Develop, keep up to date and recommend for approval by the relevant Risk Committee, appropriate policies/processes/DOIs to address financial crime risks, aligning with relevant regulatory requirements.
• Providing governance and oversight over the implementation of FCC-related policies and procedures in ASA to ensure compliance with such policies and procedures.
• Provide advice to relevant stakeholders on compliance with Group standards relating to Sanctions.
• Manage and/or resolve alerts/cases/SARs, escalated from the Transactions, Name Screening processes to the Regional Sanctions team.
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.
• Collaborate with training teams to input to training curriculum to support closing of capability gaps.
• Deliver/support Sanctions training programs to meet the training needs of the business.
• Deliver/support Sanctions training programs to meet the training needs of FCC.
• Ensure staff in FCC ASA Sanctions Investigation teams have clearly articulated and well understood roles and responsibilities through meaningful and accurate job descriptions.
Risk Management
• Maintain oversight of risk mitigating action plans.
• Understand technical aspects of systems relevant to Name and Transaction Screening and Case Management.
• Oversee the appointment of, and manage relationships with watchlist vendors as appropriate.
• Establish and maintain watch lists used for customer and transaction screening and various other due diligence and investigative purposes (local/regional internal and external).
• Provide advice on the application of risk management frameworks (e.g. ORF, GRA).
• Apply Group and FCC policies and processes (Transactions screening, client screening, risk assessment) to manage risks.
• Make recommendations (and/or implement) to relevant stakeholders on possible risk management responses to identified risks and/or findings of concerns from investigations.
• Assess risks arising from products / segments / geographies / customers / transactions.
• 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.
• Identify financial crime risk indicators through various internal/external sources that impact SCB and its clients.
• Implement Sanctions risks identification and assessment methodologies.
• Advise relevant stakeholders on outcomes of Sanctions risks identification and assessment methodologies.
• Partner with legal counsels for advice on technical matters.
• Conduct a root cause analysis on the control/other failures to ensure lessons are learned across the bank.
• Provide intelligence (to internal forums) on specific clients, client-types and emerging risk typologies.
• Oversee the review and analysis of the client base to identify and manage high risk clients, or specific country reviews.
Governance
• Attend relevant leadership meetings.
• 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.
• Support all control checks undertaken by FCC under the Operational Risk Framework (ORF).
• Be accountable for identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.
• 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 FCC ASA Sanctions Investigation teams 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.
Key Stakeholders
• Senior FCC Management in the region;
• Senior Legal and Compliance Management in the region;
• Sanctions authorities in the region;
• Regional & Functional partners in the region & across other regions.
Other Responsibilities
• Embed Here for good and Group’s brand and values in the FCC ASA Sanctions Investigation Team
• Perform other responsibilities assigned under Group, Country, Business or Functional policies and procedures.
Qualifications and Skills
Degree in Business or Banking
ACAMS
OFAC or HMT relevant experiences
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