Principal, Compliance Advisory, CIB Corporate Coverage at Standard Chartered Bank

Job Summary

• I am responsible, in my capacity as Principal, Compliance (CFCC) Advisory, CIB Corporate & Coverage, Nigeria & West Africa (“the role”) for:
• supporting the Head, CFCC Advisory, CIB Nigeria & West Africa in managing all regulatory, conduct, financial crime and compliance risks relating to the CIB CC businesses in Nigeria, Ghana and CDI (collectively referred to as “West Africa”); and
• supporting the Head, CFCC Advisory, CIB CC, AME in managing regulatory, conduct, financial crime and compliance risks relating to the CIB CC businesses in West Africa in collaboration with the country CFCC teams;
• and in each case, aligning this to the vision and strategy of the function, the Enterprise Risk Management Framework (ERMF), and delegation of authority documents where relevant.
• I have first line responsibility for the implementation of Compliance, Conduct and FCC policies and procedures for CIB CC processes in West Africa to the extent the processes have been identified as owned by the CFCC function, in line with the Group’s process universe as set out in the Group Operational Risk Framework, including activities within the processes owned by the CFCC function which are hubbed or outsourced (if any).

Responsibilities

Insofar as they relate to CIB CC compliance, financial crime and conduct, I am responsible for providing details of developments giving rise to a material risk that serious regulatory breaches or breaches of risk tolerances (as agreed by the Board from time to time) may occur and notifying any such breaches to (as appropriate):

• The relevant CCOs and MLROs in West Africa
• Head, CFCC Advisory, CIB, Nigeria & West Africa
• Head, CFCC Advisory, CIB CC, AME
• The relevant Heads of Business and stakeholders
   
• My responsibility does not encompass the operation of information technology systems used to implement any policies and procedures, which is the responsibility of the Group Chief Technology & Operations Officer.
• All references below to CIB CC businesses shall be deemed to refer to those businesses in West Africa.

Key Responsibilities

I am responsible:

• To help the Group meet its commitment of being "Here for Good" by building a sustainable framework that places CFCC best practice standards, at the forefront of the Group's agenda.
• As an independent second line risk control function, to execute the relevant aspects of the CFCC PRTFs through robust independent risk control and the provision of specialist advice and constructive challenge in a manner proportionate to the nature, scale and complexity of the CIB CC businesses.
• For the evaluation and assessment of the effectiveness of the Group’s Compliance and Financial Crime Risk Frameworks.
• To proactively support and challenge the CIB CC businesses and supporting functions to exhibit appropriate conduct, comply with regulatory, conduct, financial crime and compliance requirements and strive to achieve fair outcome for the CIB CC clients.
• For maintaining independence, delivering timely responses, and timely escalation of risks and issues where the management tolerance of the firm is exceeded.
• For maintaining constructive and effective stakeholder relationships with the relevant business and supporting functions, and to assist the Head, CFCC Advisory, CIB, Nigeria & West and Head, CFCC Advisory, CIB CC, AME to interface with and support all key stakeholders.
• For supporting the management of regulatory relationships with all of the Group’s regulators, whose rules the Group is subject to.

Strategy

• Assist the Head, CFCC Advisory, CIB, Nigeria & West Africa and Head, CFCC Advisory, CIB CC, AME to set and implement the vision, strategy and direction for CFCC Advisory CIB CC resources in West Africa, consistent with the Head of CFCC, Africa and Global Head, CFCC Advisory, CIB vision and strategy for the CFCC function, and in support of the Bank’s strategic direction and growth aspirations.
• Support and promote the culture and practice of compliance with CFCC standards (including conducting business within regulatory requirements, and to high ethical standards) within the Bank and embed a Here for Good culture and the Group Code of Conduct.

Business

• Develop a comprehensive understanding of the CIB CC business models and strategy in order to assist in providing oversight support and challenge in order to enable appropriate and sustainable CFCC outcomes.
• Build and maintain an effective and constructive relationship with all key business, CFCC and other functional stakeholders that is based on trust, capability and integrity, providing timely, responsive and quality conduct, financial crime & compliance-related advice and guidance to enable the business and functions to meet/ achieve their strategic tactical objectives.
• Provide conduct, financial crime and compliance related advice, analysis (and challenge when appropriate) in relation to CIB CC businesses, including product design, new business initiatives, bespoke projects, remedial activities (including nature, scale and rigour of past business reviews), and transactional advice.
• Provide robust challenge to senior management and all relevant business stakeholders where activities are outside risk tolerance/ appetite, escalating as necessary, until appropriate oversight and ownership is achieved including actions and plans to address any remedial action needed to come back within risk tolerance/ appetite.
• Work closely with the business and its operational teams to provide timely advice to ensure compliance with all relevant laws and regulations and support the transition to pro-active and pre-emptive CFCC risk mitigation.
• Support the resolution of competing requirements between regulations specific to CIB CC businesses (i.e. between AML regulations and data privacy/bank secrecy or information security regulations.)
• Support the establishment and maintenance of risk-based compliance frameworks and the programme for monitoring and assuring compliance that supports the transition to pro-active and pre-emptive compliance and conduct risk mitigation, in relation to the CIB CC businesses.
• Promote the culture and practice of global standards to the business, while managing local requirements.

Processes

• Act under delegation from the respective Risk Framework Owners for the principal risk types of Compliance, Conduct and FCC in discharging the responsibilities contained in the ERMF relating to CIB CC businesses to the extent that CFCC Advisory, CIB CC is the appropriate second line risk owner.
• The role holder is not responsible for CFCC first line processes unless specifically delegated by and/or agreed with the group process owner. This includes CFCC processes operated to manage risks in CIB CC businesses such as name screening or transaction monitoring.
• The role holder is not responsible to ensure that CIB CC and CFCC process owners agree their respective handoffs, which ought to be documented in a service level agreement.
• Support and maintain effective policies/processes/DOIs (including training, advice and support) to address conduct, financial crime and compliance risks across CIB CC businesses, aligning with relevant regulatory requirements.
• Provide governance and oversight over the implementation of CFCC related policies and procedures relevant to CIB CC businesses (to enable compliance with such policies and procedures).
• Provide support and challenge to CIB CC businesses to ensure that they establish and monitor appropriate processes for compliance with CFCC policies, procedures and standards (including meeting regulatory obligations and maintaining high standards of conduct).

People & Talent

• Help promote and embed a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm.
• Support the stimulation of an environment where forward planning, prioritisation, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm.
• Collaborate with training teams to input to training curriculum to support closing of capability gaps.
• Provide feedback at business, function, country and individual level as appropriate, on CFCC matters which should have a bearing on remuneration pools or individual bonuses (for senior staff).
• Drive the migration of skill, knowledge, best practice and lessons learned across the network between CFCC Advisory colleagues especially in relation to regulatory risks and compliance with relevant regulations and internal policies/standards as they pertain to CIB CC businesses.

Risk Management

• In accordance with the Group’s Enterprise Risk Management Framework, act as second line Risk Owner for appropriate and relevant CIB CC processes.
• Collaborate with the Nigeria & West Africa Country CFCC teams and Group/Regional CFCC Advisory teams to anticipate horizon risks that may have a significant impact on the Bank and develop effective strategies to mitigate such horizon risks.
• Assist in the management of CFCC Advisory, CIB CC matters, and in collaboration with the rest of the Country CFCC teams, effectively manage regulatory issues that have a significant impact on the CIB CC businesses.
• Collaborate with relevant senior managers to support the programmes for conduct, financial crime and compliance monitoring, surveillance and/or assurance for CIB CC businesses.
• In the event of serious CIB CC related regulatory breaches, or where CFCC related risk tolerances have been breached, ensure senior management and relevant regulators are informed and that actions are taken quickly to remediate and/or activities are ceased.
• Ensure proactive and timely identification, assessment, advice and dissemination of evolving regulatory changes/practices and associated regulatory, compliance and financial crime related risks, and proactive engagement in regulatory reform, in relation to CIB CC product and client related activities.
• Assist and work closely with the Group Shared Investigation Services team, as needed, in relation to investigations concerning CIB CC businesses.
• Liaise with the internal audit function to ensure that any CFCC Advisory CIB CC weakness identified by the internal audit function relating to CIB CC activities are appropriately followed up.
• Provide reports to relevant Country and Business risk and control committees and management group on key conduct, financial crime and compliance risks and issues pertaining to CIB CC businesses.
• Provide advice on the application of risk management frameworks (e.g. ERMF) and provide advice to relevant stakeholders on outcomes of risk identification and assessment methodologies.
• Support in providing oversight of risk acceptance and/or mitigating action plans relating to CIB CC businesses.
• Provide reports to relevant risk and control committees and management group on key compliance risks and issues relating to CIB CC businesses.
• Ensure global standards are understood and implemented locally, with any identified exceptions, or need for more/less stringent standards escalated for relevant joint-decision making.
• Understand technical aspects of systems relevant to CFCC Advisory, CIB CC.
• Support delivery of annual CFCC Risk Assessments, including the Compliance Risk Assessment (CRA), Product Risk Assessment (PRA), and Group Risk Assessment (GRA).
• Provide intelligence (to internal forums) on specific clients, client-types and emerging risk typologies.
• Support the review and analysis of the client base to identify and manage high risk clients, or specific country reviews.

Governance

• Attend relevant governance meetings and provide relevant reports to senior management and governance/risk committees when delegated by the Head, CFCC Advisory, CIB Nigeria & West Africa or Head, CFCC Advisory, CIB CC, AME.
• Assist in the identification and escalation of potential CFCC Advisory, CIB CC related, risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.
• Ensure appropriate CIB CC product governance measures on conduct, financial crime and compliance are in place so that product approval documents reflect all relevant regulatory requirements.
• Propose control effectiveness and efficiency improvements and simplifications where appropriate.
• Within the Group's ERMF, support the establishment and maintenance of an appropriate risk based CFCC framework for identifying, assessing, managing, monitoring, mitigating and reporting compliance (including regulatory and financial crime) risks across CIB CC businesses.
• Support management MI / trackers across all aspects of one’s coverage and responsibility to ensure all issues and matters relating to CIB CC businesses are tracked, followed, regularly assessed and reported on, including oversight of risk acceptance and/or mitigating action plans, identification and management of high risk clients or specific country reviews relating to CIB CC.

Project /Change Management

• Assist on key change programmes and projects for CFCC Advisory, CIB CC.
• Support the creation and execution of workplans specific to CFCC Advisory, CIB CC projects/ initiatives, and communicate the same to stakeholders in a regular, timely fashion to inform and seek inputs.
• Support the review of new business requirements and provide solutions for CIB CC where required.

Regulatory & Business Conduct

• Collaborate with other CFCC teams in Nigeria & West Africa in relaton to:
  • the identification and inclusion of relevant CIB CC matters for discussion in the Government & Regulatory Relationship Plans (“GRRPs”);
  • the management of regulatory inspections and identification of regulatory reform that directly relates to CIB CCbusinesses;
  • the provision of briefings and guidance to CIB CC management on relevant regulatory matters;
  • ensuring CIB CC businesses are properly prepared for routine regulatory exams, audits and supervisory inspections, as well as managing the response from the CIB CC businesses; and
  • support relevant stakeholders to respond to regulatory questions.
• Display exemplary conduct and live by the Group’s Values and Code of Conduct.
• Effectively and collaboratively identify, escalate, mitigate and resolve regulatory, conduct, financial crime and compliance matters related to CIB CC businesses.
• Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct, across the Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.

Key Stakeholders

• CCO Nigeria & West Africa
• Head, CFCC Advisory, CIB, Nigeria & West Africa
• Head, CFCC Advisory, CIB CC, AME
• Chief Compliance Officers and MLROs in Nigeria, Ghana & CDI
• Heads of CIB CC Businesses in Ghana & CDI
• Heads, FCC Centres of Excellence (e.g. Sanctions, ACC, Controls)
• Other Risk and Control Functional Heads (Risk, Audit, etc)
• Relevant Regulators

Other Responsibilities

• Perform other responsibilities assigned under Group, Country, Business or Functional policies and standards.
• Embed Here for good and Group’s brand and values in CFCC Advisory, CIB, CC in Nigeria & West Africa

Skills And Experience

• Manage Conduct Core
• Manage Risk Core
• Manage People
• CFCC Policies and Standards
• CFCC Advisory
• CFCC Review and FCC Assurance
• Surveillance (including Screening and Monitoring)
• Investigations
• Compliance Risk Assessment
• Regulatory Liaison
• Manage Change
• Manage Projects