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Compliance Data & System Analytics & Governance Manager
January 14, 2018
Maximising Effectiveness of Financial Crime Systems.
Responsible for ensuring that all financial crime systems (e.g. transaction monitoring and Sanctions are correctly implemented and managed on a group wide basis.
Principal Responsibilities, Accountabilities and Deliverables of Role:
Responsible for policies and procedures relating to the procurement, implementation, testing and ongoing management of FCC systems
Accountable executive for implementation of new or upgraded FCC systems
Partnering with technology colleagues to establish correct governance over any proposed changes in FCC systems
Responsible for post implementation ongoing FCC system optimisation
Participating in industry user groups for best practice benchmarking purposes
Responsible for ongoing data feed assurance
Responsible for performing periodic regression testing on FCC systems to ensure that all potentially suspicious activity is captured and escalated
Responsible for recommending, managing (and governing) the correct detection scenario library based upon the Bank's product and service mix, industry benchmarking and relevant FC vulnerabilities identified
Responsible for recommending (and thereafter governing) threshold/matching settings based upon testing results, industry benchmarking, relevant analysis of business practices and potential vulnerabilities
Collaborating with IT colleagues to establish and maintain a link between FCC systems and first line CDD systems so as to provide risk based alert prioritisation and a feedback loop to CDD colleagues (middle office)
Collaborating with Operations colleagues to receive feedback on alert quality and build feedback into optimisation process
Maintenance of all documentation relating to system implementation, testing and settings for audits and regulatory inspections
Managing audits and regulatory inspections of FCC systems
Designing and producing management information on FCC system effectiveness for senior management each month
Collaborating closely with FCC Risk Analytics to utilise the results of the annual enterprise wide risk assessment or monthly risk metrics in the setup of FCC systems
Provide timely, practical, value added Financial Crime advice to the business and functional units, including to overseas Compliance teams under policy ownership and/or geographic oversight, where applicable
Support the Bank in development and implementation of the Financial Crime Compliance and FC framework, policies and procedures, in partnership with the Group document owners
Demonstrate proactive identification and management of key regulatory risks and issues in areas under responsibility
Self-identification of compliance related audit issues in areas under responsibility
Acceptable rating for audits on Financial Crime or FC related issues
Closure of outstanding audit issues within stipulated time period or as agreed with Internal Audit
Support and facilitate effective functioning of Unit CFCCs under geography oversight, where applicable.
Familiarity with OCC Bulletin 2013-29 and the application thereof
Knowledge and 5-10 years of experience implementing FC systems (sanctions screening and transaction monitoring)
Familiarity with most mainstream screening systems e.g. FIRCO, Oracle
Familiarity with mainstream TM systems e.g. Oracle-Mantas, BAE-Detica, Actimize
Familiarity with leading validation service providers e.g. Crowe, Protiviti, EY, PwC
Knowledge of designing, implementing and validating quantitative models
Education / Certifications
Ideally a degree (or equivalent) in either IT or a specialist risk subject
ACAMS or ICA qualified preferred but not essential
Relevant banking experience in compliance and/or risk management
Experience in AML and Sanctions - essential
Experience of participating in regulatory inspections relating to systems and models
Exposure to working at Group level
Experience with risk models (customer, country, product and channel)
Experience of conducting FC risk assessments and the underlying methodology