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In 1965, the Standard Bank of South Africa merged with the Bank of West Africa acquiring businesses including a banking operation in Nigeria, which dated back to 1894. The name was then changed to Standard Bank of West Africa. Four years after the merger, Standard Bank Nigeria was incorporated locally to take over the business in Nigeria. In 1971, 13% of the...
Job Description
The Head of Controls manages the core operational processes executed in FCC, as well as the specialist supporting systems for surveillance/screening; to help promote and manage throughout Nigeria the culture and practice of FCC risk management within the letter and spirit of relevant laws and regulations.
Key Roles and Responsibilities
Provide oversight and management of country roles including
Head, Surveillance and Analytics Responsibilities
* System and tuning oversight for surveillance, screening and Customer Due Diligence ("CDD")
* Apply quantitative techniques to develop intelligence and tune systems to better identify and mitigate risk efficiently
* Build solutions to monitor for financial crime typologies
* Maintain documentation for systems owned in FCC, e.g. rule book
Head, Financial Crime Investigations Responsibilities
* Manage alert/cases/SARs
* Manage escalations from the business
* Manage escalations based on customer screening alerts
* Manage production orders escalated to Financial Crime Compliance ("FCC")
Head, Financial Crime Intelligence Unit Responsibilities
* Oversee media/other research and monitoring
* Maintain country watch lists
* Manage law enforcement outreach and outreach to banks on intelligence
* Support complex Group or cross-jurisdiction investigations
Head, Quality Assurance and Performance Responsibilities
* Undertake quality assurance in relation to all core Financial Crime Compliance ("FCC") processes.
* Support all control checks undertaken by FCC under the Operational Risk Framework ("ORF")
* Propose control enhancements and simplifications
* Provide resources to support work by Segments and Product/FCC/Governance/Sanctions/ABC to upgrade business controls
* Generate and monitor all metrics required for tracking operational performance of controls
Head, CDD Controls Responsibilities
* Undertake country CDD review activity executed in the regional CDD CoE
* Review Politically Exposed Persons ("PEP") files and sensitive client files
* Integrate data across processes managed in Controls relevant to the CDD review
* Escalate issues requiring business rejection/restriction
* Work with Segments and Product Financial Crime Compliance ("FCC") to escalate issues appropriately with the business at a portfolio level
Leadership and Management
* Implement and cascade the Group's policy, framework and procedures to country level
* Provide leadership to the Country FCC network as part of the Country FCC management team
* Manage outsourcing arrangements where applicable, for example FCC processes hubbed to the Group's Shared Services Centre
* Lead or influence significant programmes of work in support of the financial crime compliance objectives
* Assist in the development of an effective internal compliance culture by promoting the benefits of ethical business conduct and the benefits of compliance
Knowledge Development and Information Management
* Identify and communicate, across the business within the region, relevant changes in Controls policies, procedures and practices - recommending amendments as required
* Assist in developing FCC Controls-related training to ensure the business and support units are provided with appropriate training
Stakeholders Relations
* Partner closely with the Regional FCC Controls and their teams, ensuring there is a consistent message to country FCC, and dealing with country issues as they come up
* Support Country Compliance and FCC teams in managing regulatory relationships where FCC issues are a problem
Competencies
* Partner with the business to make decisions based on the knowledge and interpretation of current and possible future policies, practices, trends and information of financial crime
* Develop and implement financial crime compliance arrangements/frameworks (programs, policies and procedures) for bank and business lines
* Develop and implement risk and Market Integrity methodologies
* Deliver effective FCC/Sanctions/AML/ABC training programs to meet the training needs of the business
* Implement prevention and detection client due diligence (CDD, EDD and CIP) to verify the identity of clients
* Implement FCC/sanctions/AML/ABC risks identification and assessment and advise business on the findings
* Resolve suspicious activity alerts (SARs)
* Partner with Business and Operational Risk to identify and mitigate financial compliance risks
* Conclude investigations of non-compliant activities
* Review system safeguards and recommend process enhancements
* Participate in regulatory and supervisory meetings and consultations
* Resolve conflicts of interest arising from regulations and information security
* Partner with regulators locally or globally
Additional
* The role holder needs to possess extensive knowledge of the laws and regulations applicable to money laundering, such as MLPA, the Patriot Act, OFAC/HMT requirements and Suspicious Activity Reporting requirements
Role Purpose
* The Country Head of Segments and Products is to be the country subject matter expert on financial crime regulation and Regional policy to the business, and to escalate issues appropriately with the business at a portfolio level.
Key Responsibilities
* Be accountable for implementing and maintaining the FCC management framework in the country business segments together with the country FCC Segments & Products team
* Establish a structure to deliver effective advice to the businesses and country FCC
* Assist in implementing the Sanctions/ ABC program in the country
* Provide client and product advice to the business based on subject matter expertise
* Ensure effective escalation within the businesses in the region
* Ensure that the Regional Policy is rolled out in the country and that country policies are adapted to local regulatory requirements
* Support efforts to position the Bank as an industry leader in the eyes of regulators and industry stakeholders
Leadership and Management
* Provide leadership and guidance to the Segments and Products FCC team
* Develop skilled resources within the Segments and Products FCC team who can contribute to the management of FCC
* Promote and embed a compliance culture throughout the Bank
Knowledge Development and Information Management
* Provide training to the business in terms of knowledge and mitigation measures for the various client segments and products to the business
* Ensure resources are equipped with the relevant skills and capabilities to execute their tasks diligently and proficiently
Stakeholders Relations
* Partner closely with the Regional FCC Head of Segments and Products and their teams, ensuring that country policies are in compliant with Regional standards, and dealing with country issues as they come up
* Ensure through engagement with business management that there is adequate support in the businesses for necessary FCC controls, including people and systems
* Support the business in managing regulatory relationships where FCC issues are a problem
Technical Competencies:
Category Competency Proficiency Level
Execute Compliance Governance, Frameworks and Models Partner with the business to make decisions based on the knowledge and interpretation of current and possible future policies, practices, trends and information of financial crime Intermediate
Develop and implement financial crime compliance arrangements/frameworks (programs, policies and procedures) for bank and business lines Advanced
Develop and implement risk and Market Integrity methodologies Intermediate
Deliver effective FCC/Sanctions/AML/ABC training programs to meet the training needs of the business Advanced
Advise on how local culture might contribute to financial crime vulnerability Advanced
Advise on Sanctions / AML / ABC Analyse comprehensive regulatory impact of Sanctions matters on the bank's business and its operations Intermediate
Analyse regulatory impact of AML/ABC matters on the business and its operations Intermediate
Advise business on compliance & regulatory matters relating to Sanctions/AML/ABC as well as financial services industry related practices Intermediate
Evaluate products, services, geographies and customer segments of the bank that might be vulnerable to Sanction/AML/ABC and regulatory risks Advanced
Manage and Mitigate Risks Implement and follow up on strong recommendations to address high risk situations (such as dropping a long standing client/product line/country) Advanced
Manage FCC Regulatory Relationships Participate in regulatory and supervisory meetings and consultations Intermediate
Partner with legal counsels for matters regarding individual liability and country Intermediate
Partner with regulators locally or globally Intermediate
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