The FS Department has 3 distinct teams: Central Financial Security, Quality Assurance & Policy, and Fraud Prevention & Special Investigations. The incumbent will be a member of the Central Financial Security Team. They will work with other support/ control functions within Financial Security as well as Legal, RPC, HR, IT and Operations in order to effectively co-ordinate action.
The Financial Security (FS) Department provides Corporate and Investment Bank London Branch with controls and procedures in order for them to comply with the internal FS policies and procedures and the bank’s statutory objective of reducing financial crime. This covers prevention, monitoring and investigation of money laundering, terrorist financing, bribery and corruption, embargos and sanctions, and fraud. The FS Department in London also operates within the guidelines set by the FS Department in Paris and in this respect is responsible for providing that policies are implemented and complied with at the London Branch.
The FS Department has 3 distinct teams: Central Financial Security, Quality Assurance & Policy, and Fraud Prevention & Special Investigations. The incumbent will be a member of the Central Financial Security Team. They will work with other support/ control functions within Financial Security as well as Legal, RPC, HR, IT and Operations in order to effectively co-ordinate actions. They must also maintain a good working relationship with Product/Business Lines and actively work with these areas to implement realistic and effective procedures and controls.
Key Responsibilities of the department
The FS Department in the UK is responsible for:
- Developing policies, procedures, training and education;
- Taking reasonable steps to establish and maintain awareness and training;
- Developing and maintaining policy in line with evolving statutory and regulatory obligations and experience and advice from enforcement agencies;
- Acting as the primary point of contact for the UK businesses with regards to financial security matters;
- Providing opinions on higher risk customer relationships, transactions and payments;
- Representing to all external agencies (supervisors, national authorities and law enforcement agencies), and in any other third party enquiries;
- Ensuring that all parts of are complying with policy and therefore monitoring operations and development of the policy to this end;
- Obtaining and using national and international findings on money laundering and terrorist financing;
- Receiving internal reports, undertaking the internal review of all suspicions and determining if such suspicions have substance and require disclosure to the National Crime Agency (NCA);
- All contact between and London Branch and the authorities in respect of routine reports to NCA and to Customs and Police in respect of any specific investigations;
- Preparing regular reports for management on compliance with the Money Laundering Regulations;
- Ensuring that is fully compliant with the provisions of all relevant Anti-Bribery and Corruption legislation.
Key Contractor role responsibilities
The role requires involvement, as required, in assisting the Financial Security Department to fulfil its legal and regulatory obligations in the UK:
- Reviewing and opining on higher risk customer relationships;
- Assessing the need for and opining on limitations to customer relationships;
- Performing PEP assessments and opining on PEP-connected relationships, including escalating to senior management for review and approval, when necessary;
- Opining on potential higher risk transactions, having regards to sanctions, money laundering, terrorist financing and specific industry risks;
- Applying knowledge of regulatory and internal restrictions when providing client and transaction opinions;
- Providing policy and procedure advise to Front Office;
- Liaising with internal counterparts;
- Escalating identified high risk activities to line manager;
- Undertaking such ad hoc projects that are required to be undertaken by Financial Security;
- Record keeping of work undertaken as per internal procedures.
Management and reporting
- This role reports directly to the Head of Central Financial Security or in the absence of the Central Financial Security Head, to the MLRO;
Application of UK legislation and regulations in connection with all aspects of financial crime i.e. money laundering, the financing of terrorist activity and fraud. All suspicions are to be reported (without delay) directly to the MLRO and Financial Crime and Investigations Manager.
SPECIAL ROLE REQUIREMENTS:
- Detailed knowledge of UK Money Laundering Regulations, FCA Guidance and JMLSG Guidance.
- An understanding of the requirements of the EU Money Laundering Directives and their influence on the UK Money Laundering Regulations.
- Good working knowledge of HMT, EU, OFAC and other sanctions programs.
Key Internal contacts
- UK heads of legal entities;
- Overseas business line heads (e.g. Paris & New York);
- Other support function heads & staff;
- Financial Security (Paris);
- Financial Security, other overseas offices;
- Compliance functions in Paris & other overseas offices;