Department Overview & Objectives
The UK Financial Security team (UKFS) has oversight responsibilities for areas including anti-money laundering, fraud, bribery, sanctions, PEPs and high risk clients. The UK Financial Security team reports to the UK MLRO. The team members require a significant degree of ‘self-starting’. The Financial Security Compliance Officer performs a number of functions, which include:
- Supporting and assisting senior management in adherence to applicable laws and regulations as well as to high standards of business and ethical integrity
- Reviewing adequacy and completeness of customer due diligence completed by the Due Diligence Team (‘DDT’) on new-to-bank and recertified (existing) clients, particularly for compliance with applicable Policy and UK regulatory requirements
- Risk assessment for high risk escalations, including Money Laundering, Sanctions, Bribery, corruption and internal failings.
- Interpreting and advising BNP Paribas CIB London staff on applicable laws, regulations and standards.
- Training staff on relevant regulations and standards.
- Monitoring and reporting on compliance with applicable laws, regulations and standards
- Investigating and reporting on any suspected breach of applicable standards
- Role Overview & Purpose
- Within Compliance, the FSCO entails providing technical compliance advice across CIB business areas, on regulatory issues and industry changes, by assisting the business to comply with group Polies and UK regulatory requirements (i.e. with regards to anti-money laundering and applicable financial sanctions).
The FSCO will be specifically responsible for:
High Risk Escalations:
- To review PEP and other higher-risk referrals (e.g. from the London Due Diligence Team, CIB business areas in London or internationally), to assess and agree appropriate level of risk for each referral – and to ensure the UKFS Team log (or other relevant record) is updated and maintained accordingly, to ensure appropriate audit-trails for decisions.
- Review contract and deal specific documentation to asses for the presence of financial crime compliance risk (e.g. sanctions, bribery, money laundering, etc.), to identify options to mitigate identifiable risk (in consultation with other specialists – e.g. Legal).
- Represent UKFS in Client Acceptance Committees and other internal forums related to higher-risk clients, products and risk in the operating/business environment.
- Reviewing and assessing alerts generated by the bank’s monitoring systems (e.g. SUN, Actimize, etc.) where transactions or persons/bodies are referred for review and assessment of money laundering or sanctions risk.
- Provide advice consistent with (and ensuring appropriate application of) Group policies and applicable legal and regulatory requirements, particularly in relation to anti-money laundering (‘AML) and financial sanctions, anti-bribery, and related AML or Financial Crime policies and procedure.
- Maintain up-to-date awareness and understanding of UK requirements, particularly in relation to Money Laundering Regulations (or equivalent), Financial Sanctions (e.g. UK, France, EU and US OFAC) and FCA Handbook (in relation Financial Crime) and FCA Financial Crime Guidance (i.e. ‘core knowledge’).
- Applying understanding of core knowledge when supporting/advising CIB business areas and support functions.
- Competently demonstrate key AML analysis and articulate clear guidance to inform opinion on how best to identify and respond to financial crime risk, including, inter-alia, via formal reporting to the AML Committee and/or a senior business forum.
Training and Guidance:
- Support CIB development and delivery (where necessary) of financial crime training.
- Key compliance contact for the business, particularly in relation to core knowledge areas.
SAR Investigation and internal reporting:
• Report to the Nominated Officer / Investigations team any knowledge or suspicion of money laundering or terrorist financing using the bank’s internal SAR escalation process.
• Ensure up-to-date awareness and application of other internal reporting requirements covered by Group Policy and UK Law / Regulation (with regards to financial crime).
• Report any breaches of legislation or bank policy using the bank’s breach reporting procedure and escalate issue to the appropriate area.
Other (Ad hoc):
- Review and form a fact-based opinion in respect of any negative or detrimental news referred to the team for consideration.
- Maintain highly accurate records and to ensure any Management Information produced is of the highest standard.
- Ensure Management is made aware of all pressing issues in a timely fashion.
- Provide support to regular and ad-hoc internal CIB projects which require subject matter specialist input and advice/guidance (re financial crime).
- Ensure appropriate audit trail for all advice / key decisions
Skills & Experience
- Extensive experience working in a financial crime environment – including AML (not solely Customer Due Diligence), Financial Sanctions and/or anti-bribery systems and controls in a UK FCA regulated firm (preferably a CIB environment).
- Strong track record in assessing AML risk/cases and making (and documenting) informed decisions to mitigate AML risk / escalate accordingly.
- A good working knowledge of UK, EU and US sanctions regimes and an understanding of other regimes.
- A broad understanding of general AML risk issues in a CIB environment, such as, IB product, intra-jurisdictional AML and sanctions risk and client-type risk.
- A good understanding of other financial crime risk, such as, bribery and fraud is preferable.
- A detailed working knowledge of current UK regulatory environment for financial crime is essential and an understanding of future proposed changes would be desirable.
- The ability to apply a holistic approach to identifying, investigating and mitigating financial crime risk, and the ability to consider a range of risk mitigants, to present a balanced opinion of key issues to line Management.
- Excellent team player within a high pressure environment
- First class communication skills, both written and oral
- A proven ability to present a given issue to Management and argue a case accordingly
- A self-starter who requires minimal supervision
- A proactive approach to all aspects of the role will be essential
- A proven ability to make quick (but informed and rational) decisions whilst ensuring that issues/risk have been appropriately considered and mitigated