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Maintain Obligations Register for CDD in relation to AML/CTF and define the Group minimum control standards for CDD.
Working through Business FCC teams, define and agree with the relevant Process Owners and Operational Risk on the Control Standards, and the consequential Controls and the Controls Assessments (including Key Risk Indicators / Key Control Indicators / Control Sample Tests) to be established and monitored for key client processes including client on-boarding, review and off-boarding, in line with the requirements of the Operational Risk Framework (ORF).
Monitor the overall CDD Control Assessments, and provide inputs and recommendations to Business FCC teams.
Define the CDD controls to be tested by Continuous Monitoring and Review team and determine the grading structure.
Define the CDD controls to be tested by the Group FCC Risk Assessment (GRA) and determine the grading structure.
Liaise with the following in relation to the overall key framework and issues relating to reviews and standards
FCC Assurance team
Group Internal Audit
Liaison and management of specific countries and cases to be conducted by Business FCC teams or region/ country FCC teams.
Support the business to ensure that systems which support CDD are aligned to the procedural requirements.
Business [Responsibilities related to the delivery of business and / or financial objectives]
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 [Processes for which the role is responsible under the ORF as 1st & 2nd line; for executing / completing, and for supervising]
Develop, keep up to date and recommend for approval by the relevant approval authority, appropriate CDD control standards to address financial crime risks, aligning with relevant regulatory requirements.
Document and maintain CDD control standards.
Provide advice to relevant stakeholders on compliance with Group standards relating to CDD.
People and Talent [Responsibilities related to people and talent matters]
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.
Ensure staff in Department have clearly articulated and well understood roles and responsibilities through meaningful and accurate job descriptions.
Risk Management [Responsibilities Under Risk Management Framework – both execution and supervisory]
Support the Bank's risk mitigating action plans by collaborating with the Bank's FCC technical, controls and subject matter experts to ensure existing systems, processes, risk assessments and practices on clients – from on-boarding, risk rating, screening and on-going monitoring to prohibitions, hard-holds and off-boarding – are aligned with industry best practices and standards and close out any compliance gaps.
Inform senior management 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.
Anticipate horizon risks in the area of financial crime that may have a significant impact on the Group and develop effective strategies to mitigate such horizon risks
Develop and/or implement risk management frameworks (e.g. ORF, GRA) including methodology, governance / process, analysis and action planning.
Advise relevant stakeholders on outcomes of [AML/Sanctions/ABC] risks identification and assessment methodologies.
Attend relevant leadership meetings where deputized.
Support and provide oversight of FCC region/country/function in collaboration with the respective FCC Client Segment.
In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure senior management are informed and that actions are taken quickly to remediate and/or activities are ceased.
Translate lessons learned from audit findings, FCC assurance activities and specific investigations into CDD Standards.
Propose control improvements, enhancements and simplifications where appropriate.
Be accountable for identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.
Define metrics and/or key risk indicators (KRI) especially for AML and Sanctions in relation to CDD.
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 [country / business unit / function/XXX [team] 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.
Support relevant stakeholders to respond to regulatory questions.