Senior Compliance Manager

JOB PURPOSE/SUMMARY

AML/CFT ROLE:

Responsible to manage AML/CFT and Sanctions compliance programme for CBAM by:

• Ensuring that AML/CFT and Sanctions policies and procedures are in line with the QFCRA's AML/CFT Rules and the relevant local/international requirements;
• Preparing and submitting regular/ periodic and ad-hoc AML/CFT notifications to the QFCRA's AML/CFT department;
• Providing AML/CFT advisory to CBAM's BOD, senior management and customer facing functions;
• Ensuring the detection of ML/TF/PF and Sanctions violation related suspicious activities and filing an STR to QFIU;
• Performing annual/periodic BRA and effectiveness assessment of CBAM's AML/CFT programme;
• Preparing/ Submitting periodic AML/CFT reports to the Firm's Senior Management and the Regulatory Authority.

REGULATORY COMPLIANCE ROLE:

Responsible to prepare, manage and monitor end-to-end compliance monitoring programme for CBAM by:

• Ensuring that Regulatory Compliance policies and procedures are in line with the QFCRA's relevant rules and regulations;
• Performing periodic gap analysis to ensure that CBAM policies, procedures, systems and controls adequately meet the regulatory requirements;
• Providing compliance advice to business to ensure that their conduct is in line with the QFCRA's regulatory imperatives.

COMPLIANCE OVERSIGHT ROLE FOR REGULATED SUBSIDIARIES:

Responsible to ensure that the Group AML/CFT policies and standards are consistently applied across all regulated subsidiaries of the Bank and stricter AML/CFT requirements (of home or host country) are implemented across all regulated subsidiaries to the legally allowed extent.

KEY ACCOUNTABILITIES/RESPONSIBILITES

A) AML/CFT

General AML/CFT Role and Responsibilities

1. Overseeing the implementation of the firm's AML/CFT policies, procedures, systems and controls in relation to the relevant regulatory requirements;
2. Ensuring that appropriate policies, procedures, systems and controls (PPSCs) are developed, established and maintained across the firm to monitor the firm's day-to-day operations;
3. Assessing, and regularly reviewing, the adequacy and effectiveness of the policies, procedures, systems and controls in preventing money laundering and terrorism financing;
4. Being the firm's key person in implementing the firm's AML/CFT strategies in relation to dealing with the QFC Regulatory Authority;
5. Supporting and coordinating senior management focus on managing the firm's money laundering and terrorism financing risks in individual business areas;
6. Helping to ensure that the firm's wider responsibility for preventing money laundering and terrorism financing is addressed centrally;
7. Promoting a firm-wide view to be taken of the need for AML/CFT monitoring and accountability.

Specific AML/CFT Role and Responsibilities

1. Receiving, investigating and assessing internal suspicious transaction reports (STRs) for the firm;
2. Making suspicious transaction reports to the FIU and notifying the Regulator about STRs;
3. Acting as central point of contact between the firm, the QFIU, the Regulator and other State authorities, in relation to AML and CFT issues;
4. Responding promptly to any request for information by the FIU, the Regulator and other State authorities in relation to AML and CFT issues;
5. Receiving and acting on government, regulatory and international findings about AML and CFT issues;
6. Executing the Firm's AML/CFT training programme and monitoring the appropriateness and effectiveness of the Firm's AML/CFT training programme;
7. Reporting to the firm's senior management on AML and CFT issues;
8. Keeping the Deputy MLRO informed of significant AML/CFT developments (whether internal or external);
9. Exercising any other functions given to the MLRO, whether under the AML/CFT Law, QFCRA's AML/CFT Rules or any other regulatory guideline;
10. Bringing relevant AML/CFT regulatory developments to the attention of the firm's senior management and maintain the record of any action taken or not taken as the result of such notifications to the senior management;
11. Providing or arranging the provision of accurate information/ documents to Internal Auditor, External Auditor and Regulatory Authority during AML/CFT review of the Firm;
12. Ensuring that the proposed Risk Mitigation Plan (proposed by Internal Auditor, External Auditor and/or Regulatory Authority) is appropriately and timely executed/ completed;
13. Participating and contributing to the Group wide AML/CFT risk assessment exercise;
14. Ensuring that the regulatory notifications are timely submitted to the Regulatory Authorities which include but not limited to the followings:

• Annual MLRO Report;
• Form Q25 – Annual AML/CFT Return;
• Form Q25 –NAMLC Data Collection Form;
• Assessment report on the effectiveness of the Firm's AML/CFT controls;
• Form Q07 - Notification of significant events related to ML/TF/PF;
• Public Prosecutor Department/ NCTC's listing, freezing and unblocking orders.

B) REGULATORY COMPLIANCE:

Regulatory Compliance related roles and responsibilities include but not limited to the followings:

1. Analyzing/ assessing the nature, size and complexity of the Firm for the development of a suitable Regulatory Compliance Policy and Procedures.
2. Developing, communicating and implementing the Firm's Regulatory Compliance Policy.
3. Ensuring that Regulatory Compliance policies and procedures are updated in line with the QFCRA's relevant rules and regulations.
4. Performing periodic gap analysis to ensure that CBAM policies, procedures, systems and controls adequately meet the regulatory requirement.
5. Providing compliance advice to business to ensure that their conduct is in line with the QFCRA's regulatory imperatives.
6. Developing and monitoring compliance controls.
7. Keeping the Firm and its Senior Management updated with the key regulatory developments.
8. Supporting the Firm's staff in maintaining compliance and assisting the governing body in developing the culture of compliance.
9. Drafting, finalizing and presenting compliance reports.
10. Providing Advice on the regulatory implications concerning new products, services, channels and geographies.
11. Planning and executing a Compliance training programme for the Firm.
12. Maintaining a cooperative and effective relationship with the Regulator and other competent authorities such as QFIU.
13. Dealing with the customer complaints in line with the Firm's Compliance Policy;
14. Ensuring that the regulatory notifications are timely submitted to the Regulatory Authorities which include but not limited to the followings:

• Form Q03 – Controlled function application;
• Form Q12 - Controlled function withdrawal;
• Form Q13 - Application by an Authorised Firm to Vary the Scope or Withdraw its Authorisation;
• Form Q07 - Notification of significant events;
• Form Q05 - Application for Waiver or Modification;
• Annual Product Return.

C) COMPLIANCE OVERSIGHT OF REGULATED SUBSIDAIRIES

1. Responsible to ensure that Group AML/CFT policies and standards are consistently applied across all regulated subsidiaries of the Bank.
2. Ensuring that the Subsidiary Compliance Oversight Policy and Procedures are up to date in accordance with the parent firm's policies and procedures;
3. Ensuring that the stricter regulatory imperatives of home or host countries gets implemented in the relevant subsidiary.
4. Ensure that oversight function is carried out as per the set procedures and periodic oversight reports are effectively reviewed and reported (if necessary) to the Bank's CRC.
5. Ensure that all significant developments and events get reported to the Bank's BRCC.
6. Ensure that all relevant home country's regulatory developments and imperatives gets implanted across all domestic and foreign subsidiaries.

Required Qualifications:

• Bachelor degree in accounting, law, business administration or equivalent;
• CAMS (Certified Anti Money Laundering Specialist);
• CISI QFC Rules and Regulations or CISI DIFC Rules and Regulations or equivalent regulatory qualification.

Required Experience:

10 -12 years' relevant experience in AML/CFT and Regulatory Compliance including at least 5 years in the position of MLRO for a Financial Institution.

Must have a detailed understanding of QFCRA's AML/CFT and Regulatory Compliance rules and regulations applicable for a regulated entity in the QFC.