JOB REPORTING TO : Head of Compliance and Governance
JOB PURPOSE
The Purpose of the job is to support and define the bank’s AML & Sanctions Monitoring strategy and goals across the bank, guiding the program. To ensure the bank has relevant, up-to-date, and adequate policies, procedures, processes, and strong controls to support the management of Financial Crime Compliance (FCC) Risks; FCC risks include Money Laundering, Terrorism Financing, Sanctions, and Anti-Bribery & Corruptions Risks. Oversee the first line of defense in implementing the requisite AML & Sanctions controls, processes, and systems to comply with applicable laws, rules, and regulations, as well as frameworks, policies, and procedures.
KEY RESPONSIBILITIES:
FCC Program Management
- Champion effective implementation of methods to identify, assess, and mitigate AML/CFT/CPF, and Sanction risks across the Group.
- Provide oversight and support to the bank's Compliance Risk Infrastructure that monitors Suspicious Activity, AML, and Sanctions violations.
- Harmonize to the greatest extent possible AML & Sanctions Compliance policies, procedures, and Risk Assessments across the Enterprise.
- Design and support implementation of Enterprise KYC/CDD programs consistent with AML regulatory requirements and the bank’s specific risk profile.
- Conduct examinations and assessments of the bank’s AML/CPF/CFT and Sanctions Compliance programs: Develop an annual schedule and continuous process for compliance testing and monitoring activities across all business line functions.
- Oversee and ensure the production of timely and effective AML, Sanctions, and Transaction Monitoring-related MIs and other applicable information to the Director of Risk & Compliance, Management Operational Risk Committees, and Board Risk Committee.
- Support the design, development, and implementation of strategies, standards, and procedures to support the AML/CFT/CPF Data Governance program while facilitating adherence to the bank’s Enterprise Data Governance framework for data policies, standards, and practices.
Enterprise Risk Assessment & Control:
- Provide oversight to the bank's Compliance Risk Infrastructure: Safeguarding operational and compliance risks governance, policies, and standards are enforced by all lines of businesses and support units.
- Participate in Annual Compliance Risk Assessments - play a key role in the assessment through all stages. Provide quarterly risk assessment and updates to the Board and management on the closure of audit issues. nafasi za kazi
- Review new products and services to ensure appropriate consideration of key AML/CFT/CPF and Sanction compliance risks and any necessary mitigating controls.
- Implement and coordinate Compliance Risk Management Processes while challenging the First Line of Defence (FLOD) on the effectiveness of controls: Drive finalization of risk category and subcategory framework for Risk and Control Self Assessments, Product Risk Assessments, and Process Level Assessments.
- Design and implement Risk Based Alerts Scoring Models: Lead the development and maintenance of the Enterprise AML Transaction Monitoring strategies, including scenario development and rules optimization to support AML and Forensic Risk Identifications.
- Design and Implement vendor's due Diligence Framework: Develop vendor's risk categorizations and implement Due Diligence commensurate with risk levels.
- Consistent with AML regulations and policy recommend De-Risking initiatives to management based on increased customers’ or Product Risks Profile against established bank’s AML risk appetite.
- Design risk-based Financial Crime Compliance Training and ensure training requirements are implemented across the group by staff.
- Perform other duties as assigned by the Head of Compliance & Governance.
EDUCATION REQUIREMENTS EXPERIENCE, KNOWLEDGE, AND SKILLS REQUIRED
- Degree from a reputable University preferably in Law, Economics, Finance, Risk Management, or a related discipline.
- Holder of ACAMS Certifications or intention to be certified within six months of employment.
- 7 + years of experience in the banking industry or regulatory environment; at least 5 years in AML/CFT and OFAC/ Economic Sanctions compliance.
- Experience in dealing with regulatory matters and confident interaction with Management, Board, and Regulators.
- Significant experience in Risk and Operations Management together with business management, from a frontline role in Commercial Banking
- Ability to identify, escalate and communicate issues to management in an effective and succinct manner
- Strong knowledge of AML laws & Sanctions regulations and their application.
- Excellent project management and organizational skills and capability to handle multiple projects at one time
- Advanced knowledge of Excel, Access, Word, PowerPoint, and Projects.
- Excellent written, and verbal communication, and analytical skills
- High level of moral and Ethical standards Generally applicable to the bank