VP
FINANCIAL CRIME DEPARTMENT OVERVIEW
The Wealth division's Financial Crime Team is located in London and Glasgow, although working directly with Regional Advisors and MLRO’s globally. The team’s primary responsibilities are interpreting and implementing AML, Sanctions and KYC policies, managing the subsequent controls and working closely with the Wealth businesses to provide direction and interpretation of regulatory requirements.
The team’s role incorporates a Policy element, technical definition and ongoing advice and guidance, as well as maintaining oversight of the key Financial Crime controls. Management Information is used to track emerging patterns in areas of Financial Crime which is used to improve business processes and identify risks for senior management and business heads.
CORE ACCOUNTABILITIES
The role holder is primarily responsible for managing the Glasgow based sanctions team and ensuring its ongoing development to support the effective management of day to day sanctions risk throughout the Wealth business. This will include existing activities such as management of payment screening processes globally, input as SMEs to any change initiatives; oversight of remediation associated with any policy updates and MI analysts as well as agreed changes in activity to support improved management or oversight of sanctions or financial crime risks.
The role holder will support the Head of Wealth Sanctions as in the deployment of the following responsibilities:
General
- Team prioritisation and management of workload
- Coaching and development of all team members
- Input to development and implementation of Sanctions Policy and standards on behalf of the Wealth division.
- Provide thought leadership on Sanctions related issues
- Support implementation Sanctions strategy
- Responsible for reviewing and updating local Sanctions policy and procedures where required
- Direct and assist the operational Sanctions screening teams in continuing to maintain the appropriate tuning of Sanctions screening systems and updating the policy and procedures accordingly where required
- Support the team in providing day to day advice on Sanction policy matters
- Proactively identify improvements needed within the relevant local Systems and Controls (keeping Group advised appropriately), and continuously seek more efficient and effective performance of the overall framework. Direct relevant work and escalate appropriately
- Ensure that Sanctions matters are correctly referred and follow appropriate escalation routes, while involving the relevant stakeholders early and fully
Reporting
- Accurately create and maintain records for all Sanctions exceptions, breaches, list notices, circumventions, dispensations and waivers
- Maintain and report key MI relating to exceptions, breaches/circumventions, dispensations and waivers and list notices in accordance with local and Group reporting timelines
- Report Sanctions breaches in accordance with local and Group required timelines, and ensure key stakeholders are appropriately updated via the breach escalation process
Management Leadership:
The role holder will work with the Head of Sanctions to develop and define the vision for the Glasgow team and the supporting strategy. Implement the strategy, effectively leading the team through any upskilling and changes as required. This will include ensuring any changes are effectively managed within the team and with external stakeholders.
Group Sanctions Programme and Cease and Desist Activity:
The role holder will support the Glasgow team and business stakeholders through Regulatory, Legislative and sanctions initiatives, working with Operations, the Business and Technology to ensure all stakeholders are engaged throughout the lifecycle of change and development. This will include providing accurate advice and making risk based decisions on the direction of Financial Crime programmes and updating the Management and Steering Committees as appropriate.
Financial Crime Investigations:
The role holder will support and manage ad-hoc investigations globally, as well as supplying support to all business areas in the management of incidents, audit findings and screening solution changes.
ROLE REQUIREMENTS
Professional/technical experience
Understanding of OFAC, HMT, EU, UN and other jurisdictional sanctions laws, regulations, regulatory expectations and industry best practice. This should include knowledge of Global Sanctions regimes and requirements and AML regulations, in addition to;
- Excellent experience in delivering critical Business initiatives
- Excellent experience of employing change management best practices and disciplines
- Knowledge of Group Sanctions and AML policies
- Knowledge of UK, offshore and international banking requirements processes and policies
- Knowledge of Wealth divisions customer base and segments
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