| The strategy within FCC is 'to prove that the Bank is leading the way in combating financial crime, whilst providing quality service for our clients'. The role of FCC Assurance is to provide the Bank's Senior Management with the evidence that proves that the strategy is succeeding. |
As a member of the FCC Assurance team, the FCC Assurance Associate Director is responsible for the planning, execution, evaluation, reporting and advancement of FCC Assurance reviews (the "Review") and periodic testing of key compliance controls, processes and procedures to demonstrate compliance with Group and local requirements addressing money laundering, terrorist financing, sanctions and anti-corruption and bribery.
The FCC Assurance Associate Director is expected to implement and maintain a sound, prudent and effective regime for the reviewing, testing, tracking and reporting of compliance, risk management, governance and regulatory issues specific to money laundering, terrorist financing, embargo & sanctions, exposure to politically exposed persons, corruption and bribery. The role is also responsible to report and provide assurance that all identified compliance and risk management issues are being tracked to satisfactory and are being dealt with in an effective manner.
Key Roles and Responsibilities
Financial Crime Compliance Assurance
- To assist the Regions Head of FCC Assurance in relation to all FCC assurance activities, including the planning, coordination, execution, evaluation, drafting of and issuing of assurance review reports;
- To provide input into the preparation of the annual risk based FCC assurance plans covering appropriate Lines of Business in the applicable regions and Standard Chartered Bank ("SCB") geographies;
- Understand the Group Risk Assessment results and ensure the identified risks are taken into account when designing the Review;
- Provide a critical, risk based insight for the design of scopes for each Review using the FCC Assurance Methodology:
- Provide suggestions for topics and scope for each review. Ensure that suggestions improve the Review's risk focus.
- Read audit and regulatory recommendations and ensure tests include the current status of remediation efforts.
- Prior to each Review, the FCC assurance review stages must be followed:
- Planning - Pre Review Preparation
- Scope out Review far enough in advance that FCC and the Business can arrange the appropriate resourcing to be available;
- Socialise with the relevant business areas explaining the purpose of the Review; and
- Fact finding.
Plan the Review in accordance with the FCC Assurance Methodology and agree with the RH of FCC Assurance;
- Identify, read and ensure coverage of applicable local laws/regulations in either Group or local Policies/Procedures;
- Identify and obtain documents, reports, and system access required to complete the Review;
- Meet with stakeholders to discuss their concerns;
- Prepare a list of attributes to be tested and document detailed test methodology;
- Provide documented results and conclusion for each of the fieldwork test steps; and
- Retain a record of work completed in order to satisfy internal and external regulatory expectations.
- Document the results of all tests, interviews and observations to reflect the knowledge gained during the Review and support any issue raised;
- Consider reports issued by regulators, Group Internal Audit ("GIA") and Compliance Assurance and review Management's remediation efforts;
- Draft report findings, including ratings in conformance with the FCC Assurance Methodology, with a view to discussing remedial actions with Action Owners;
- Determine the root cause of issues reported in accordance with FCC Assurance Methodology;
- Agree distribution of the final report;
- Discuss work performed and reported findings with the RH of FCC Assurance.
- Issue Tracking:
- Track progress and resolution of findings of all issues on the Issues Tracker until validated and closed.
- Record validation rational in assurance work papers.
- Assist the RH of FCC Assurance and the Global Head of FCC Assurance gather information for management information reporting as necessary.
- Leadership and management
- Establish strong working relationships with key stakeholders such as the Global, Regional and Country Heads of FCC, FCC Management and Managers of other business units subject to FCC Assurance reviews.
FCC assurance fieldwork may require international travel for extended periods of time.
- Partner with the business to make decisions based on the knowledge and interpretation of current and possible future policies, practices, trends and information of financial crime
- Develop and implement financial crime compliance arrangements/frameworks (programs, policies and procedures) for bank and business lines
- Partner with Business and Operational Risk to identify and mitigate financial compliance risks
- Review system safeguards and recommend process enhancements
- Participate in regulatory and supervisory meetings and consultations where required
- Partner with regulators locally or globally where required.
Qualifications and Skills
- Strong assurance, audit or regulatory inspection experience within a financial services environment (preferably in Anti Money Laundering ("AML"), Sanctions, Anti-Bribery and Corruption).
- Knowledge of Compliance and local laws and regulations relating to FCC and an understanding of best practice risk management techniques and frameworks relevant to the banking industry.
- Strong experience of assurance in an international environment.
- Excellent interpersonal, oral and written communication skills.
- Multi cultural awareness and sensitivity.
- Strong analytical skills and sound judgement.
- Strong team player.
- Strong influencing skills.
- Drive, independence and enthusiasm.
- Certified Anti Money Laundering Specialist ("CAMS") or International Compliance Association Diploma (ICA Dip AML) Certification (Preferred).
- Certified Financial Crime Specialist ("CFCS") Certification (Optional).
Target Proficiency Level:
FCC Policies and Standards
Surveillance (including Screening and Monitoring)
Compliance Risk Assessment