Director, FCSO Country Head at Standard Chartered Bank Kenya

Job Summary

• To discharge the key responsibilities of the Process Owner at country level for the Financial Crime Surveillance Operations (FCSO) processes as set out in the Enterprise Risk Management Forum (ERMF), as it relates to:
• Identification and management of the FCSO processes and associated risks including activities which are carried out by other businesses or functions, or which are hubbed or outsourced
• Implementing the Root Cause Self-Assessment (RCSA) to monitor the effectiveness of the controls and standards governing the end-to-end process
• Being responsible to the Process Universe Owner, Risk Framework or Policy Owners, and implementing the control requirements applicable to the process
• Escalating significant risks and issues to the Process Universe Owners, relevant Risk Framework Owner (RFO) or Policy Owners.

Strategy

• Support the implementation of the Financial Crime Compliance (FCC) Strategy by escalating appropriate FCC and Anti Money Laundering (AML) issues and executing activities in line with guidance documents.
• Set the strategy for casework and queue management for the FCSO team.
• Ensure to senior management that Standard Chartered Bank’s operations in are in line with regulatory expectations and Group requirements.

Business

• Support relevant stakeholders to make decisions based on current and possible future policies, practices, and trends.
• Keep track of and provide advice to relevant stakeholders on the interpretation and application of regulatory expectations, laws, best practices and policies related to AML surveillance.
• Develop a good understanding the Bank’s range of products and services.
• Propose the risks related to the Surveillance and Operations activity.
• Effectively supervise Country FCSO team for day-to-day BAU activities.
• Ensure timely reporting and escalation of significant AML/ Combating Terrorism Financing (CTF) issues to FCSO Management Team and Country RFO / Head of FCC/ Country Money Laundering Compliance Officer (CMLCO).
• Identify, assess, monitor and escalate risks and issues to Second Line and the Senior Management.
• Ensure the suitability and quality of case data maintained on enterprise case management systems.
• Understand technical aspects of systems relevant to Client Due Diligence (CDD), Client Risk Assessments, Name and Transaction Screening, AML Monitoring and Case Management.
• Input into optimisation of risk and data analytic tools/techniques to tune relevant detection scenarios, and screening and monitoring systems.
• Review and assess existing system and controls relevant to FCSO processes performed in country to ascertain operational performance and effectiveness.
• Ensure that the relevant lists and database as used by the screening systems are up to date and meet local country requirements.
• Prepare and cascade lessons learned from audit findings, Country Financial Crime Compliance (CFCC) assurance activities and specific investigations.
• Propose control improvements, enhancements and simplifications where appropriate.
• Support all control checks undertaken by FCSO under the Operational Risk Framework (ORF).

Processes

• Daily supervision of the Watchlist Management, including but not limited to; additions/deletions to the Group Sanctions/FCC Lists and also ’s local Lists, ensure timely execution by direct reports for needed amendements to list entries, watchlist reconcilliation when and as needed, supporting as Country Lead for any Group LM projects or exercises.
• Day to day management of regulatory reporting on transactions, and responding to the regulator as required.
• Day to day management of legal orders / production orders including responding to law enforcement and conducting related investigations where appropriate.
• Day to day management, oversight and processing of Transaction Monitoring (TM), Transaction Screening (TS) and Name Screening (NS) cases in line with Assess Analyse ACT (AAA) procedures.
• Processing and concluding TM, TS & NS cases allocated in a timely manner within agreed Turn Around Time (TAT) whilst maintaining Quality Control/Quality Assurance results in line with Group and local expectations. Ensuring the direct reports complete cases in a timely manner and to the appropriate quality standards.
• Develop, keep up to date and recommend enhancement of appropriate policies/processes/ Departmental Operating Instructions (DOI) to address financial crime risks, aligning with relevant regulatory requirements.
• Provide advice to relevant stakeholders on compliance with Group standards relating to AML surveillance.
• Monitor the performance of all direct reports and the wider team in meeting agreed TAT and Quality Control expectations, and proactively identify any key trends that indicate a deterioration in team performance.
• Country Process Owner for all AA processes, and present in the relevant risk committee.
• Own and design FCC AA processes, controls and standards for adhering to Risk Type Frameworks and Policies set by the Second Line relating to Group Transaction Monitoring and Group Screening Standards.
• Ensure systems and processes meet risk data aggregation, risk reporting and data quality requirements set by the Second Line.
• Implementation of investigation, surveillance and intelligence standards set by regulators and the Group FCC function (via processes defined by Group FCSO, Group Process Owner (GPO), and Country FCC.
• Reporting Internal Suspicious Activity Reports (SAR’s) for cases escalated through FCSO screening or transaction monitoring processes to Country FCC.
• Ownership of end-to-end Country FCSO Processes as defined in the ERMF.

People & Talent

• Promote a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm.
• Ensure forward planning, prioritisation, deadline management, streamlined workflows and efficient work practices are the norm.
• Support direct reports in achieving their annual objectives and provide guidance and advice to address any knowledge or performance shortfalls identified.
• Assist direct reports in achieving their desired learning and development objectives and provide feedback and direction on suitable courses and opportunities.
• Ensure staff in FCSO have clearly articulated and well understood roles and responsibilities through meaninful and accurate job descriptions.

Governance

• Propose control improvements, enhancements and simplifications where appropriate.
• Support all control checks undertaken by FCC under the Operational Risk Framework (ORF).
• Analyse and interpret data to produce reports that help the bank identify and manage emerging areas of risk / vulnerability and support in remediation actions within the FCC function.
• Be accountable for identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.

Regulatory & Business Conduct

• Display exemplary conduct and live by the Group’s Values and Code of Conduct.
• Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct, across Standard Chartered Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.
• Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.

Other Responsibilities

• Embed Here for good and Group’s brand and values in Kenya FCSO team; Perform other responsibilities assigned under Group, Country, Business or Functional policies and procedures; Deliver advice, guidance and training to the various business teams across the bank as required; Provide back up support to team colleagues and Country Head of FCC / CMLCO as required.

Risk Management

• Support the day to day management of Production Orders, List Management, TM, TS & NS activity by developing and deploying sound analytical skills to produce balanced judgements in relation to financial crime risk including concise rationale and clear follow on action.
• Overseeing the work of the direct reports covering TM, TS and NS and the case dispositions recommended by them.
• Overseeing the work of the direct reports assigned with all Production Order and List Management activities, the handling of their assignments, the quality of executed actions as well as the promptness.
• Ensure detection scenarios are fit-for-purpose, providing feedback where false positives or immediate emerging risks are identified.
• Understand technical aspects of systems relevant to List Management, CDD, Client Risk Assessments, Name and Transaction Screening, Trade, AML Monitoring and Case Management.
• Identify and highlight any compliance gaps in existing controls or relevant systems.
• Apply Group and FCC policies and processes (TM, TS & NS, AML surveillance, client screening, risk assessment) to manage risks.
• Assess risks arising from products / segments / geographies / customers / transactions.
• Manage interaction / communication / meetings with stakeholders and other departments as and when needed in order to mitigate risks.
• Advise relevant stakeholders on outcomes of any risk identification and assessment methodologies.
• Defining, gathering and processing risk data related to FCSO processes to meet the Group’s risk reporting requirements.

Key stakeholders

• Regional Head FCSO, and GBS FCSO
• Country Head of FCC / CMLCO and FCC
• Country CFCC Advisory & Governance
• Regional CFCC Team
• Business Segments – senior management teams
• Country Business Operational Risk
• Country Business Operations and teams
• Group List Management Team / Surveillance Parameter Optimization and Tuning (SPOT) and Product Monitoring Management (PMM) Teams
• Regulators including the Monetary Authority of (MAS) and the Commercial Affairs Department (CAD) of the Police Force
• The Association of Banks in (ABS)
• Peers in other banks / industry

Skills and Experience

• Compliance Policies and Standards
• Compliance Advisory
• Compliance Review and FCC Assurance
• Surveillance (including Screening and Monitoring)
• Investigations
• Compliance Risk Assessment
• Regulatory Liaison

Qualifications

• Bachelor’s degree or higher
• ACAMS