Head, Financial Crime Compliance (FCC) - Nigeria and West Africa at Standard Chartered Bank

The Area and Country Head of FCC is to manage the Area execution of the Anti-Money Laundering (“AML”), Sanctions and Anti-Bribery and Corruption (“ABC”) programs according to Group and local standards, and has a direct management of those FCC country Area capabilities that are hubbed into a regional utility.
   
Key Roles and Responsibilities
   
Overall Responsibilities

• Ensure that Group, Region, Area  and Country senior management and regulators are provided with assurance that AML/CFT, Sanctions and ABC risks are managed in the Area in line with the Group’s financial crime compliance frameworks and risk tolerance, and local regulatory expectations
• Own the execution of the Group’s financial crime compliance frameworks for AML/CFT, Sanctions and ABC in the Area
• Ensure that countries identify additional requirements for FCC beyond Group standards and that those additional requirements are implemented as additional controls in the country
• Review the case for dispensation from Group standards where requested by the business
• Assess risks in the Area through the implementation of a risk assessment process and ensure that an appropriate action plan is in place to address control weaknesses, or that risks are escalated for acceptance to appropriate governance forums
• Provide second line oversight of controls owned in the business that are relevant to financial crime, including CDD and transaction screening
• Provide investigative research, advice and decision making in relation to higher risk relationships and transactions escalated in accordance with Group processes agreed with Group policy and procedure owners for FCC, e.g. high risk clients identified through CDD process; high risk transactions escalated in line with the Group’s sanctions controls
• Execute processes for which FCC is the owner in accordance with the Group’s design, amended as appropriate to meet expectations of local regulators, including AML surveillance, client screening, risk assessment
• Manage the escalation of significant events (e.g. SARs, sanctions cases) with Group stakeholders and external parties as appropriate
• Support the Group’s and Region’s network through interaction with colleagues in other Areas within the Africa Region to manage risks efficiently, effectively and consistently across the Group
• Identify and share best practices with across countries in the Area and Region and with the Group
• Undertake assurance activities in collaboration with colleagues in the business, FCC Compliance Monitoring and GIA
• Oversee the appointment of specialist vendors as appropriate

Leadership & Management

• Contribute to the Area  FCC Leadership team
• Raise the profile of SCB in the Area  as leading the way in tackling financial crime, for example through regional focus/benchmarking groups (ACAMS etc.)
• Where services are hubbed by countries to a Regional centre, the Area Head of FCC is accountable to Country Heads of L&C for those hubbed services provided (e.g. AML surveillance and customer screening)
• Act as key contact point for Heads (of ABC, Sanctions, Governance, Controls, Segments & Products) in integrating risk management strategy into an operational reality
• Form and chair a  Area practice / working group to integrate Area  Heads into a single, global team as part of the FCC regional management
• Ensure there is capacity in line with the Group’s objective for the management of financial crime risks

Knowledge Development and Information Management

• Prepare lessons learnt documents (from SARs & AML Investigations) and share with business advisory teams and FCC Senior Management so they can be cascaded to other Area and country  FCC teams
• Ensure provision of appropriate FCR awareness & training (i.e. SAR and financial crime trends, AML investigation outcomes, lessons learned) within region through regional training managers
• Prepare and manage Area  metrics/reports

Stakeholders Relations

• Provide support to countries on regulatory relationship management and exams relating to FCC in the Area