It has developed a risk-based approach designed to ensure that every reasonable measure (including policies, procedures, instructions, IT systems, monitoring methods, awareness and training activities, objective-setting, incentives, deterrent measures and sanctions) is taken in order to avoid or reduce the possibility of such compliance risks occurring and to minimise the damage if such a risk should nonetheless occur
Supporting the Country Compliance Head/MLRO and the Director, Financial Crime, the FCO will support the advisory, monitoring, policy, training and regulatory change processes in connection with financial crime.
The FCO will be dedicated to doing this in a way that:
- upholds the firm's legal, regulatory, ethical standards and reputation;
- fosters partnerships, collaboration and the compliance culture throughout the firm;
- heightens awareness of relevant AML, sanctions and financial crime regulatory issues; and
- delivers consistent guidance, advice and innovative solutions; and
- provides regulatory advice, in all matters relating to AML and Financial Crime to the key business lines in the UK
Objectives of the Function
To provide the Director, Financial Crime with support in delivering Business As Usual financial crime tasks, to support the bank's objective in managing to its financial crime risk, including AML, sanctions, anti-bribery, corruption and fraud, within the context of the financial crime framework of the firm. This role will also necessitate significant close liaison with Head Office Compliance, to ensure that global policies are understood and reflect UK requirements.
Results and Core Activities
To assist the Director, Financial Crime with a proactive, expert and effective regulatory compliance advisory service.
Training & Collaboration
Work effectively at all levels across ABN AMRO to provide support and assistance, including tailoring various means of financial crime training for different audiences.
Policies and Procedures
Maintain adequate policies and procedures sufficient to achieve compliance with ABN AMRO's obligations under relevant regulations and for countering the risk that the business line might be used to further financial crime, supporting the Director of Financial Crime on implementing policy changes within the business units of the UK.
Monitoring and Reporting
Where there are dependencies on Head Office, support the Director of Financial Crime and businesses in ensuring that management information is received on a timely basis, in accordance with agreed requirements, in order that adequate UK oversight can be maintained.
Perform routine AML monitoring tasks in order to ensure that policies and procedures are being followed, and that issues identified are being escalated appropriately.
Provide input and establish where required periodic and other relevant reports/management information, including input into the annual Compliance Plan and Financial Crime Risk Assessment, to be presented to the ExCo on an annual basis.
Risk Identification and Assessment
Support both the Director, Financial Crime and the Director, Policy & Regulatory Developments, so that, on a systematic basis, it can be evidenced that the bank is keeping abreast of current EU, FCA, DNB, ECB and JMLSG Financial Crime regulations, requirements and expectations..
Knowledge and Experience
Required level and content of education:
- A strong academic record.
- A related financial crime qualifications, such as the CISI Diploma in Financial Crime, or equivalent. Any specific professional qualifications in relation to AML / financial crime would be useful.
Required employment experience:
- Ability to communicate clearly and concisely on complex regulatory compliance issues at all levels, both internally and externally.
- Ability to produce written documents articulating key aspects of regulatory change, along with full impact analysis on relevant business areas.
- Ability to resolve conflict and deal with confrontation through tact and skill.
- Ability to work independently, but a strong team player.
- Assertive, analytical, accurate and tenacious.
- Display initiative in identifying and presenting solutions to support activities and plans.
- Proven ability to work to deadlines and prioritise deliverables.
- Forward looking in terms of how BAU activities can be made more efficient.
- Practical and pro-active approach.
- Self-motivated and well organised.
- A deep understanding of relevant existing, and emerging regulatory requirements.
- A strong and demonstrated ability to assess, mange and enhance management information.
- Excellent command of the English language both written and orally
- High level of IT literacy.
- Attention to detail.