Reporting to the Regional Head of Financial Crime Compliance AML (Head of FCC AML), the Head of Financial Crime Compliance AML Office (Head of FCC AML Office)leads a team responsible for the oversight of the implementation and ongoing governance of the AML Program to ensure effective implementation of policies and procedures, consistent compliance reporting to the Board through the AML EXCO, FCC MANCO and STEERCO, analysis of MI across all pillars of the AML Program and LOB for reporting to the aforementioned country committees and Global AML Office, as required.
Impact on the Business
Provide oversight of the AML Program:
Lead the dispensation process for AML with Canada. Review and assess dispensations submitted, forming a recommendation for sign-off by the Head of FCC AML.
Establish agreed action plans with the respective Lines of Business/ region that will reduce risk associated with dispensations granted and the time period for which the dispensation is required. Track and monitor that action plans are adhered to by Lines of business/ Regions in accordance with the terms of the approval.
Ensure that variances introduced by business lines or geographies are monitored and considered for ongoing enhancements of the program, to ensure regional consistency in the management of risk.
Ensure standards and policy documents are up to date and reviewed periodically, in accordance with program requirements of other trigger events.
Supports the Affiliates Due Diligence Program (ADDP). Establish and manage the mechanism through which the ADDP considers the enterprise wide view of HBCA
Establish the framework for AML reporting through the appropriate local or global governance committee, encompassing Management Information to be reported on regionally, by LoB.
Ensure prioritization of the development of accurate, frequent and comprehensive AML management information with GCMI.
Assess the Canadian AML Management Information to provide a strategic appraisal of emerging risk trends, opportunities and risks, evaluating the effectiveness of the program and forming recommendations of mitigating actions as required.
Lead the preparation of the annual MLRO report based upon the EWRA. Provide trend analysis on MI and other Governance information reporting.
Liaise with the Monitor’s Office to manage requests for information from Global AML.
Coordination of inquiries on behalf of authorities and industry bodies on AML matters so as to ensure that the Group’s Canadian Regional interests are represented and professional and positive relationships are fostered.
Lead communications for the AML function, including gaining support for change initiatives through the AML Executive Committee; town halls for the immediate AML function; Senior Stakeholder briefings; and regional/country level briefings. Establish and execute upon broader employee communications plans to support the implementation of the AML Program.
Support the Regional Head of AML in establishing and leading the overall AML Plan.
Partner with the FCC Program and other partners to shape the AML Plan, ensuring that there are clear goals, benefits, scope, governance and delivery structure with planning, design, and consultation with key stakeholders in the regional AML Teams and Partner functions.
Ensure prioritization of AML Projects, to ensure focus on highest impact risk management initiatives, responding to audit and regulatory findings along with the results of the EWRA.
Lead coordination of projects, stakeholder involvement and attendance of related steering committees, ensuring alignment of AML initiatives with other functions within FCC and RC.
Represent the AML Executive Committee at related Steering Committees, acting as an effective escalation point for AML, facilitating issue resolution.
Manage a team leading special projects and resolution of other escalated items within the broader remit of the AML function
Partner with HR to ensure development and implementation of the AML human capital plan, including establishment of core competencies for all AML function roles, capacity planning, succession planning, and oversight of the year end calibration process for the AML Function
Customers / Stakeholders
Work closely with the Canadian Financial Crime Function, Global Standards, Global Businesses and other Group Functions to promote the AML Program and obtain their support for the program, the investment and operating model that it requires.
Provide detailed briefings and updates to the Group Head of AML Office and other members of Senior Group Management, ensuring that management is appropriately advised of material AML compliance issues.
Drive consistency in messaging throughout the organization and building a culture of transparency between AML compliance and the first line of Defense.
Ensure that the Lines of Business and Regional/Country AML Offices, under the leadership of the role holder, effectively communicate and provide transparency to their respective businesses over AML Risk, the program and its related Management Information.
Respond swiftly and clearly to Group/ Senior Executive evolving requests and requirements.
Deliver fair outcomes for our customers and ensure own conduct maintains the orderly and transparent operation of financial markets.
Leadership & Teamwork
Provide leadership over the AML Office. Strong leadership skills to manage a diverse team.
Ensure the AML Office team appropriately escalates material incidents and other areas of concern, leading issue resolution and building a culture of a responsive Canadian Regional team, close to the Business.
Foster positive and professional working relationships with the business, Canadian Regional FCC function, GMO and other senior managers throughout the Group.
Act as a change leader and ensure that the Canadian Regional AML function is a coordinated and responsive center of expertise to deliver/cascade the AML Program to the Business and support functions
Provide leadership and coordination of project activities that span across teams within the Canadian Regional AML function. Review and ensure appropriate resource allocation within the team, to meet deliverables and develop staff.
Promote an atmosphere of collaboration not competition, both within the AML function and across to other functions/ partners, responsive to suggestions from other areas, regions and businesses.
Lead and develop an effective team through communication, performance management, development plans and reward/recognition practices.
Promote an environment that supports diversity and reflects the HSBC brand.
Operational Effectiveness & Control
Promotes and takes accountability for AML Program governance, reporting and communication, delivered through the AML office structure.
Provide timely and accurate AML reporting, through which to evaluate the AML Program, risks and issues.
Review and constructively challenge project / workstream status reports.
Capture key lessons learnt from various Regions, countries and lines of business and ensure these are taken onboard by the Canadian Regional AML function to drive the continuous improvement of AML Program.
Ensure that action plans are in place and evolve to reflect EWRA results, audit and assurance findings.
Develop a control framework to ensure that key program changes are reported against and implementation tracked.
Drive continued alignment and coordination between AML and other areas of Financial Crime.
Ensure that all employees are aware of and effectively identify and manage applicable money laundering (ML), terrorist financing (TF), sanctions and reputational risks.
Complete other responsibilities, as assigned.
To govern the AML Program in a highly regulated jurisdiction across three global businesses, in an environment of rapid change and with extensive review by the HSBC Monitor.
To drive change in culture with respect to the management of AML Risk, in accordance with the three lines of Defense model.
To manage the inter-linked and competing demands of developing, implementing and improving strategic Financial Crime Compliance systems and controls on a Group wide basis.
To build a team able to deliver at pace and develop a sustainable operating model for AML.
To respond to and anticipate the requirements of law and regulation across the Group’s diverse geographies and businesses.
The jobholder is required to deal with issues for which there is no clear cut solution whilst still being able to provide judgment and clear direction.
The nature of the role requires close working contact with senior executives across HSBC Bank Canada, Group businesses and functions together with executives from regulatory bodies.
Management of Risk
Ensure compliance of both general and anti-money laundering and anti-terrorist financing (AML/ATF) compliance controls as well as operational risk controls in accordance with HSBC or regulatory standards and policies; and optimize relations with regulators by addressing any issues.
The jobholder is accountable for ensuring that the compliance and reputational risk standards are in accordance with the AML Program.
The jobholder will also continually reassess the operational risks associated with the role and inherent in the business, taking account of changing economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new regulation.
This will be achieved by ensuring all actions take account of the likelihood of operational risk occurring. Also by addressing any areas of concern in conjunction with line management and/or the appropriate department.
The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organization.
This will be achieved by consistently displaying the behaviors that form part of the HSBC Values and culture and adhering to HSBC risk policies and procedures, including notification and escalation of any concerns and taking required action in relation to points raised by audit and/or external regulators.
The jobholder is responsible for managing and mitigating operational risks in their day to day operations. In executing these responsibilities, the Group has adopted risk management and internal control structure referred to as the ‘Three Lines of Defense’. The jobholder should ensure they understand their position within the Three Lines of Defense, and act accordingly in line with operational risk policy, escalating in a timely manner where they are unsure of actions required.
Through the implementation the Global AML, Sanctions and ABC Policies, supporting Guidance, and Line of Business Procedures the jobholder will make informed decisions in accordance with the core principles of HSBC’s Financial Crime Risk Appetite.
Observation of Internal Controls
Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.
The jobholder will also adhere to and be able to demonstrate adherence to internal controls. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators.
This will be achieved by adhering to all relevant processes/procedures and by liaising with Compliance department about new business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimizing relations with regulators.
The jobholder will implement measures to contain compliance risk across the business area. This will be achieved by liaising with Compliance department about business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimizing relations with regulators.
Bachelor degree or equivalent experience. CAMS certification is preferred.
Experienced professional with 7-10 years of broad knowledge of AML issues across the financial services industry.
Deep understanding and knowledge of HSBC’s activities, products, processes and systems, able to evidence the ability to navigate through the Group’s businesses and structure
Proven ability to work across lines of business and regions whilst maintaining a global perspective
Able to evaluate risk and mitigating controls and consider their Business Impact
Evidence of ability to make key strategic decisions
Very strong analytical, decision-making, lateral thinking skills, with demonstrated ability to identify links between programs of work
Strong communication, presentation and influencing skills
Ability to think innovatively, shaping and communicating new concepts
Proven ability to confidently work with and influence senior stakeholders and business sponsors
Experience in leading and managing a team in a complex matrixed environment
Senior leadership qualities, highly motivated and stress tolerant, capable of working under pressure, with demonstrated effectiveness of working at pace to tight deadlines
Strong people management and leadership experience
Experience in prioritizing competing demands and communicating these effectively
Job Field : Risk Management
Primary Location : North America-Canada-Ontario-Toronto
Schedule : Full-time Shift : Day Job
Type of Vacancy : Country vacancy
Job Posting : 06-Dec-2016, 10:27:34 Unposting Date : 14-Dec-2016, 23:59:00
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