PERM - CPD - Financial Crime Compliance Advisory - Assistant Vice President

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Section 1 - Details

Job Title / Corporate Title

Financial Crime Compliance Advisory - Assistant Vice President

Department / Group

Compliance Department Financial Crime General / SMBC BI

Responsible to / Line Manager

Line Manager's Role, Job Title / Corporate Title.

Financial Crime Advisory. Vice President

Direct Reports

N/a

Location

London

Date Prepared

May 2024 update

Certification regime

Out of scope

Section 2 - Purpose of Job

To assist in identifying where the products and services offered by SMBC BI are or may be used for criminal activities.

To provide the EMEA region with advice and guidance with respect to the financial crime risk involving transactions, clients or other business which the Bank could be exposed to, whilst meeting legal and regulatory requirements.

To provide advice and guidance to key stakeholders in the first line of defence on financial crime escalations.

To identify where enhancements to the financial crime framework could be made.

To work collaboratively with colleagues dealing with sanctions escalations

Conduct reviews of individuals, corporate entities, business sectors, individual countries, products etc. to identify from a financial crime and reputational risk perspective any key risks the Banks may face.

Ensure that management information is accurately obtained and analysed to help assess the financial crime risks.

Section 3 - Background

As a regulated entity the Bank has both a regulatory and statutory obligation to ensure it implements systems and controls necessary to mitigate the risks of the firm being used in connection with money laundering and / or the financing of terrorism or fraud.

The role sits within the Banks 2nd line of defence and as such is responsible for supporting both Front Office and back-office departments by conducting detailed reviews of financial crime matters escalated to CPD - FCG. Working in partnership with 1st line teams to ensure that the Bank can undertake business whilst sufficiently mitigating any underlying financial crime risks.

Section 4 - Facts / Scale

Main interfaces/relationships: Head and Deputy Head of FCC, Front office departments, OAD staff within EMEA. Additionally, EMEA MLROs & RCCO on ad hoc basis.

Primary remit: 2nd line activities, as defined by CPD - FCG policies, in relation to financial crime advisory referrals and reviews. To continually risk assess and escalate accordingly when required.

Secondary remit: Undertake role of SME for at least one area of financial crime as directed. Provide advice, guidance, assistance and training to EMEA staff in line with SME responsibilities.

The AVP role holder will also be required to support the EMEA Head and Deputy Head of FCC with respect to strategic initiatives, in order to ensure that the Bank's financial crime systems and controls framework remains fit for purpose.

Section 5 - Accountabilities & Responsibilities

• Responding to enquiries from the business in a timely manner.
• Providing advice and guidance to EMEA front office departments to mitigate financial crime risk associated with regards to current and potential customers and proposed trades / transactions, supplier engagements and corporate hospitality.
• To review and assess the appropriateness of financial crime related clauses contained within financing documentation/ agreements, to ensure transactions fall within the bank's risk appetite.
• To assist in the writing of applicable policies and procedures.
• To escalate effectively to the EMEA Head/Deputy Head of FCC/ Manager of FCC Advisory, any other matters that require further guidance.
• Identify developing themes, assist in building control frameworks which proactively prevent or detect financial crime. Keep fully apprised of proposed changes to legislation, directives and guidance, and ensure that key points are communicated to Head/Deputy Head of FCC.
• Collate MI and draft reports in preparation for internal committees.
• Draft Suspicious Activity Reports (SARs) for submission to the Nominated Officer/MLRO/NCA.
• In conjunction with CPD Training unit produce and deliver specialist training with regards to financial crime across EMEA.
• In addition to the normal responsibilities over the department in the EMEA offices, the role holder is responsible for day-to-day provision of services to SMBC London Branch based on the Agreement for the Provision of Services between SMBC London Branch and SMBC BI

Section 6 - Knowledge, Skills, Experience & Qualifications

• Understanding and practical ability to apply the management of financial crime risks within the UK Banking environment.
• Inquisitive, motivated and highly trustworthy with an ability to work with the minimum of direct supervision, experienced in dealing with highly confidential material.
• Ability to independently conduct reviews of complex referrals
• Strong analytical skills, capable of making logical assessments based upon factual data.
• Thorough understanding of the Bank's products and services.
• Excellent verbal and written communication skills, especially when faced with challenge.
• Strong ability to appropriately prioritise tasks in a high-risk environment.
• An International Compliance Association or other recognised professional qualification in financial crime.
• Ability to acknowledge that there is often a need to be a member of more than one team. Tactful, diplomatic, customer focused individual.
• Ability to act as financial crime SME on behalf of CPD-FCG.
• Knowledge of Proceeds of Crime Act 2002, Bribery Act 2010, Fraud Act 2006.
• Knowledge of the wider financial crime landscape - UK and global.
• Well organised with excellent ability to prioritise conflicting work whilst retaining an excellent attention to detail.

Section 7 - Challenges

The role holder will be required to collate, analyse and summarise a large amount of complex data working in time sensitive situations where attention to detail is critical whilst effectively managing conflicting demands and expectations placed upon them.

Section 8 - Dual-Hatting

1. Dual-Hat Details (only required if different to the employing entity details)

Dual-Hat Job Title:

Dual-Hat Line Manager:

Dual-Hat Direct Reports:

Dual-Hat Certification Regime:

1. Dual-Hat Roles and Responsibilities

You will be required, from time to time, to undertake tasks on behalf of the dual-hat entity, as necessary.

1. Dual-Hat Conflict of Interest

• You will have responsibilities for both SMBC BI and Nikko CM
• You will be required to perform your duties and responsibilities on an entity neutral basis, without favour
• You are required to follow regulatory requirements applicable to ensure each business is appropriately supported and to maintain the legal entity integrity of each of SMBC BI and Nikko CM
• Working terms are dictated by functional mandates in place between SMBCE and Nikko CM and any other relevant agreements entered into between SMBC BI and Nikko CM
• You have responsibility for identifying and resolving where there may be a difference or conflict in needs between SMBC BI and Nikko CM, escalating to your manager/Compliance officer where required

We value the uniqueness of professional and personal, backgrounds and perspectives as they play a vital role in continuing our sustainable growth as an organisation. If you're in need of reasonable adjustment to the recruitment process due to disability or long-term condition, just let your recruiter know.