Compliance Analyst – High-Risk Accounts, Financial Institutions & Sanctions Oversight at Prime Bank Kenya

Job purpose:

To independently oversee and strengthen the bank’s control framework for high-risk customers, financial institution relationships, country risk exposure, sanctions governance, and financial crime monitoring. The role ensures accurate KYC/UBO compliance, robust FI due diligence, effective transaction monitoring, and proactive sanctions and country-risk management, while providing clear guidance to the business and protecting the bank from ML/TF/PF, sanctions, reputational, and correspondent banking risks.

Key responsibilities:

High-Risk Customer Portfolio Oversight

• Maintain and review the High-Risk Accounts Portfolio, including PEPs, NGOs, real estate, forex bureaus, money remitters, casinos, cross-border traders, and other elevated-risk sectors.
• Ensure KYC, Source of Funds/Wealth, and risk profiles are complete, current, and aligned to customer activity.
• Confirm correct system risk markings and flags across core banking and AML systems.
• Track overdue reviews, deficiencies, and remediation actions; escalate persistent gaps for restriction or exit consideration.

Beneficial Ownership (UBO) & Complex Structures

• Validate UBO structures for high-risk customers and FIs in line with regulatory thresholds and control tests.
• Review ownership charts, nominee arrangements, trusts, and layered structures.
• Ensure UBO data is accurately captured in systems and refreshed upon ownership changes.
• Escalate opaque or high-risk structures for Enhanced Due Diligence (EDD).

Financial Institutions (FI) Due Diligence & Risk Assessment

• Conduct and maintain annual FI risk assessments, covering jurisdictional risk, products, customers, channels, AML controls, and sanctions governance.
• Perform FI Due Diligence (FIDD) and EDD for correspondent banks, remittance partners, PSPs, fintechs etc.
• Maintain complete FI due diligence files and ensure timely refresh.
• Support onboarding, renewal, and periodic review of FI relationships.

Country Risk, Sanctions & Watchlist Governance

• Maintain and periodically update the Bank’s High-Risk Countries List, aligned to:
  • FATF black/grey lists
  • Sanctions regimes (OFAC, UN, EU)
  • CBK and internal risk assessments
• Communicate country risk updates promptly to branches, business units, Treasury, and Operations.
• Maintain and govern internal Restricted / Blacklists, including:
  • Sanctioned entities and individuals
  • Blacklisted customers and counterparties
  • Persons of Interest (POI) lists
  • Restricted sectors and corridors
• Maintain and update a Crypto Exchange & Virtual Asset Risk List, identifying:
  • Prohibited or restricted exchanges
  • High-risk VASP jurisdictions
  • Approved/monitored crypto-related exposures (if any)
• Ensure all lists are accurately configured in screening and transaction monitoring systems.
• Track regulatory updates and ensure timely system and policy alignment.

RFI, Correspondence & External Inquiries

• Coordinate and review Requests for Information (RFIs) from correspondent banks, regulators, and partners.
• Prepare accurate, consistent, and well-supported responses on:
  • KYC and UBO
  • AML controls and transaction flows
• Sanctions screening and country risk management
• Track RFI timelines, escalations, and closure.

Regulatory, Management & Audit Support

• Prepare inputs for:
  • High-risk portfolio reports
  • FI exposure summaries
  • Sanctions and country-risk dashboards
• Support EWRA updates, inspections, and audits with evidence-based documentation.
• Maintain audit trails for sanctions decisions, list updates, and escalations.

Controls, Data Quality & Governance

• Ensure accuracy and consistency of:
  • Customer risk ratings
  • Country risk classifications
• Sanctions and blacklist configurations
• Identify control gaps and recommend enhancements to systems, SOPs, and escalation thresholds.

Core Competencies & Behavioural Attributes

• Analytical Rigor: Strong quantitative ability.
• Attention to Detail: Zero-tolerance environment for errors.
• Ethics & Independence: High integrity, unbiased judgment, adherence to AML/CFT obligations, and strong confidentiality discipline.
• Problem Solving: Ability to resolve trade breaks, data mismatches, AML alerts, and limit issues efficiently.
• Technical Mastery: Strong AML/CFT/CPF mastery.
• Communication: Clear, concise, and professional reporting.
• Collaboration & Relationship Management: Strong cross-functional engagement.
• Learning Agility: Ability to adapt to new systems, regulatory changes, and market dynamics.