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Compliance Officer (Anti-Bribery & Corruption, Gift & Invitation and Due Diligence Focus)
November 8, 2020
In Asia Pacific, BNP Paribas is one of the best-positioned international financial institutions with an uninterrupted presence since 1860. Currently with over 17,000 employees* and a presence in 13 markets, BNP Paribas provides corporates, institutional and private investors with product and service solutions tailored to their specific needs. It offers a wide range of financial services covering corporate & institutional banking, wealth management, asset management, insurance, as well as retail banking and consumer financing through strategic partnerships.
Worldwide, BNP Paribas has a presence in 73 markets with more than 196,000 employees. It has key positions in its three main activities: Domestic Markets and International Financial Services (whose retail-banking networks and financial services are covered by Retail Banking & Services) and Corporate & Institutional Banking, which serves two client franchises: corporate clients and institutional investors. Asia Pacific is a key strategic region for BNP Paribas and it continues to develop its franchise in the region.
BNP Paribas offers you an exciting career in an international business environment that is fast-paced, diverse and focuses on creating high-value relationships with our clients. We offer competitive salary and benefits, as well as a working environment where you're valued as part of the team.
* excluding partnerships
The integrity and professional ethics ("PE") of each BNP Paribas employee forms the basic building block of BNP Paribas Group Code of Conduct. In this regard, the Asia Pacific Professional Ethics & Investigations ("APAC PE & I") within Compliance aims to promote a sound business and ethical culture within BNP Paribas through the following:- a. Ensure consistency in the integration of the Code of Conduct into the Region's action principles for employees from PE perspective; b. Implement PE related rules, processes, and controls for misconduct prevention; c. Handle PE breaches and whistleblowing alerts in accordance with internal guidelines and requirements; d. Support BNP Paribas entities across APAC in critical investigations; and e. Provide timely reporting to all territory management on the PE breaches and investigations for appropriate remedial actions to be taken.
APAC Anti-Bribery & Corruption, Gift & Invitation, Due Diligence Team ("AGD Team") is a sub-team of APAC PE &I. AGD team has a wide remit to ensure all BNP Paribas APAC staff are compliant with and fully conversant to all laws, regulations and internal guidelines in the areas of Anti-Bribery & Corruption ("AB&C"), Gifts & Invitations ("G&I") and Due Diligence ("DD").
Anti-Bribery & Corruption ("AB&C") The French National Assembly adopted a law known as "SAPIN II" in June 2017. The law requires French companies and groups to take measures to prevent and detect acts of corruption and influence peddling, committed both in France and abroad.
"SAPIN II" has an extra-territorial effect and sets out the required scope of anti-corruption programme for French companies / groups including risk mapping, due diligence procedures, internal controls, internal alert set-up, disciplinary measures and training.
The team is to have a dedicated person assigned as APAC Anti-Bribery & Corruption Compliance Officer ("ABCCO") to be responsible for liaison with various stakeholders, management of the anti-corruption programme, and advising on and monitoring of the implementation of measures required.
Gifts and Invitations ("G&I") The team covers G&I to ensure proper framework in place. The team is to ensure that all G&Is offered or received by staff of the Bank must be reasonable, in that the amount or value would not likely compromise the staff's independence of judgment, to cast doubt on his / her integrity, or to appear disproportionate compared with the business relationship in question.
Due Diligence ("DD") At times, business or functions request for independent review or investigation against existing / potential clients, suppliers, staff or any other individual or entity connected to the Bank whose background requires further examination (e.g. negative news or dubious reputation). The team conducts enhanced due diligence and provide findings.
All team members are expected to have general knowledge about the policies and activities covered by PE&I, and be ready to assist, as and when required.
The AGD team members have responsibility to ensure smooth running of activities related to ABC, G&I, and DD, including but not limited to the following:-
Anti-Bribery & Corruption
Follow Group guidelines and instructions on the anti-corruption programme, and liaise with territory AB&C compliance points of contact regarding procedures issued by the Group;
Coordinate ABC Risk Assessment across APAC;
Advise on and monitor the implementation of the AB&C measures in APAC countries;
Create close links with GFS Paris for any AB&C issues and generate a close working relationship with FS, KYC and AML staff in APAC region;
Liaise with other Compliance teams and relevant stakeholders in order to gather information for reporting to the Group;
Participate and contribute in Group and Regional projects on AB&C issues;
Work with Group Compliance and Human Resources to ensure that training is assigned to staff, especially to staff of functions most exposed to corruption risk;
Gifts & Invitations
Contribute to Bank's new Gifts, Invitations, Other Advantages ("GIOA") project;
Ensure local adaption of GI/GIOA, subject to local constraints;
Approve staff's G&I requests for relevant APAC territories and manifest the G&I Register;
Provide advisory on G&I related matters to APAC territories;
Participate in the re-balancing of LOD1 & LOD2;
Conduct second level control testing related to gifts & invitations;
Coordinate with CCRM on controls and related projects;
Participate in the development of professional G&I Approval Tools in their parameter;
Participate in PE Risk Assessment;
Participate and contribute in Group and Regional projects on G&I issues;
Due Diligence Reviews/Investigations
Handle DD requests and conduct necessary searches and relevant tasks;
To communicate and understand the requirements of the research request with the requestor
To investigate and conduct open source research on suppliers, intermediaries, potential clients/clients through public records, commercial databases, media information, in house databases and discreet site visits to assess risks and identify if any derogatory information (i.e. Criminal records, bankruptcy records etc.) on the subjects
Ensure that DD investigations / reviews on alleged breaches of Code of Conduct and ethics are properly managed in a professional and consistent manner in close liaison with Compliance, Inspection Generale ("IG") and Legal as may be required
Provide investigation support and assistance to the Whistleblowing, Investigation & Conduct ("WIC") team to work on investigation cases (not limited to Compliance related but others such as sexual harassment, bullying / intimidation, unexplained work absences etc.), if required;
Construct comprehensive written reports that highlight concerning activity and offer solutions as to identify control weaknesses;
Handle internal and external missions / inspections on AB&C / G&I/ DD matters;
Issue and update regional Compliance bulletins, policies, and procedures, in relation to AB&C / G&I/ DD, as and when required;
Set up regular meetings with AB&C / G&I/ DD contacts in APAC;
Provide periodic training sessions on AB&C / G&I/ DD, as and when required;
Keep abreast of developments on AB&C / G&I/ DD in APAC; and
Any other task as directed by the Manager, APAC PE & I - AGD/ APAC Head of PE & I.
Competencies (Technical / Behavioural)
Knowledge of "SAPIN II" provisions, as well as anti-corruption laws and regulations within different territories in the APAC Region;
Extensive experience in AB&C / DD reviews, and internal staff misconduct investigations;
Extensive experience in Gifts & Invitations matters;
Relevant compliance experience in the areas of professional ethics in the finance industry
Highest level of integrity and moral standards;
Ability to prioritise work depending on exigencies of the Bank;
Ability to work independently, consistently and constructively on complex cases under pressure;
Ability and willingness to travel; and
Excellent written and spoken English / Chinese (Cantonese & Mandarin)/ any other Asian language (used in any APAC territory in which the Bank has a presence).
Membership of Certified Fraud Examiners or other equivalent qualification;
Experience with a governmental investigative body (e.g. a Commercial Crime Bureau, Criminal Investigation Department, Financial Investigation Unit, Anti-Corruption Authority, Tax Authority or Law Enforcement Agency) in the APAC Region;
Previous exposure to internal control frameworks (e.g. audit); and
Proficiency in other Asian language (s).
Specific Qualifications Required
University graduate with major in Law, Commerce, Economics, Finance or Accounting; and
For junior role, at least 1 year of banking and / or regulatory experience. For more senior role, at least 5 years of banking and / or regulatory experience, ideally 2 years' exposure to AB&C area.