Know Your Client & Client Onboarding Associate

Who we are

United by a sense of purpose towards our customers – to be a trusted partner for the long-term – and our universal banking platform in EMEA, SMBC Group has an international growth agenda and award-winning products, meaning we provide exciting opportunities to work on a diverse range of projects and initiatives. We deliver a full suite of corporate finance products and solutions to our customers as well as investment banking and advisory services, and a range of innovative solutions in global capital markets. Read on to find out how you could enhance your skills and gain valuable experience, by joining us to support our clients transition to a sustainable future.

Role Summary

The primary purpose of this role is to act within the first line of defence in the three lines of defence model. This model is a risk management framework that divides responsibilities into three distinct lines to ensure comprehensive risk management and compliance. The first line of defence, where this role is situated, involves the operational management of risks. Specifically, this role is designed to protect the Bank by identifying Financial Crime and Sanctions risks associated with the onboarding of new clients and conducting periodic due diligence on all existing clients using a risk-based approach.

Key Responsibilities:

1. Risk Identification and Mitigation:

   • The role involves identifying potential financial crime risks, such as money laundering, fraud, and sanctions violations, during the client onboarding process. This includes assessing the client's background, business activities, and financial transactions to ensure they do not pose a risk to the Bank.
   • Conducting periodic reviews of existing clients to ensure ongoing compliance with regulatory requirements and internal policies. This involves re-evaluating the client's risk profile and updating their information as necessary.

2. Data Consistency and Accuracy:

   • Ensuring that client information registered in both the Enterprise Information Center (EIC) and the Know Your Customer (KYC) system (ACCORD) is consistent and accurately completed. This includes verifying customer classifications required for regulatory purposes.
   • Ensuring that all regulatory notices and customer communications are stored in the EIC and have been correctly acknowledged by the customer where necessary.

3. Escalation and Reporting:

   • Escalating and formally reporting any client or client activity that appears to expose the Bank to sanctions or financial crime risks to the Compliance and Prevention Department (CPD) second line for advice and guidance. This includes submitting a Suspicious Activity Report (SAR) where necessary.

Business Area

The function of this role is to process client KYC files in relation to the onboarding of new clients into the Bank. This includes, but is not limited to, the investigation and documentation of the client's ownership structure and ultimate beneficial owner. The role also involves identifying and investigating any associated Politically Exposed Persons (PEPs), providing detailed rationale for their materiality and classification for approval by the Money Laundering Reporting Officer (MLRO).

This role does not have direct reports from a management perspective. However, it involves significant interaction with various teams and departments across the Bank.

Key Interactions:

1. FCMO Teams EMEA-wide:

   • Contact with FCMO teams across the EMEA region for information sharing and cooperation regarding client data, especially where GIC processes are in place.

2. Front Office Representatives:

   • Daily interaction with representatives of the Front Office, providing help and advice regarding KYC requirements and the documentation to be sourced.

3. Financial Crime Group of CPD:

   • Daily interaction with the Financial Crime Group of CPD, especially the MLRO, for file escalations related to PEP/Negative News assessments or general guidance and advice. Collaboration with the CPD FCG Sanctions and Forensic teams for sanctions or other financial crime aspects.

4. SMBC BI London FCMO Staff:

   • Interactions with Front Office teams and CPD teams in London and Paris due to the scope and coverage of SMBC BI London FCMO staff.

Position Description

Detailed Responsibilities:

1. Ownership Structure and Beneficial Ownership:

   • Investigating and documenting the client's ownership structure to identify the ultimate beneficial owner. This involves understanding the client's corporate structure, including any subsidiaries or parent companies, and identifying individuals who have significant control over the client.

2. Politically Exposed Persons (PEPs):

   • Identifying and investigating any associated PEPs. This includes assessing the risk posed by PEPs, who are individuals with prominent public functions, and providing detailed rationale for their materiality and classification for approval by the MLRO.

3. Negative News Screening:

   • Examining and classifying negative news articles related to the client. This involves assessing the credibility and relevance of the news articles and providing a rationale for the classifications. The role also includes ongoing monitoring of serious negative news articles to ensure the client's risk profile remains accurate.

4. Sanctions and Financial Crime Exposure:

   • Checking and escalating any sanctions-related exposure. This involves assessing whether the client or their activities are subject to international sanctions and taking appropriate action to mitigate any risks.

5. Client Documentation and Relationship Management:

   • Liaising with Relationship Managers (RMs) regarding their KYC answers and the quality, consistency, accuracy, and suitability of client documentation. This includes reviewing the Risk Assessment Matrix (RAM) calculation and considering its suitability or whether a written representation should be made to the MLRO for a RAM override to more accurately reflect the client's perceived risk.
   • If the risk is deemed high, the role involves checking the RM's enhanced due diligence assessment.

6. Regulatory Classifications:

   • Checking all relevant EIC fields, including MiFID classifications, to ensure compliance with regulatory requirements.

The role requires a comprehensive understanding of the regulatory framework associated with Financial Crime, Sanctions, and Anti-Money Laundering (AML). Keeping abreast of changes to this framework is essential.

Required Knowledge and Skills:

1. Regulatory Framework:

   • A good understanding of the regulatory framework associated with Financial Crime, Sanctions, and AML. This includes knowledge of relevant laws, regulations, and guidelines, such as the USA PATRIOT Act, the UK Money Laundering Regulations, and the EU's Fourth Anti-Money Laundering Directive.

2. Customer Due Diligence (CDD):

   • Previous experience working within a CDD team in a financial institution is beneficial. This includes experience in conducting KYC checks, identifying beneficial owners, and assessing the risk posed by clients.

3. Qualifications:

   • Externally recognized qualifications in relation to AML and Customer Due Diligence are desirable but not a prerequisite. Examples include ICA Certificates and ACAMS certifications.

4. Communication Skills:

   • Excellent communication skills, both written and verbal. The ability to communicate complex issues and regulatory requirements to all

Competencies

What we offer

For all the expertise and experience you bring to help us make a difference, it’s only sustainable if we support you to build your career and be your best self so we offer competitive company benefits, centred around promoting positive well-bring and work-life balance. We also believe in fostering a diverse and inclusive work environment, where all team members perspectives and contributions are valued. Initiatives in place which promote a diverse and inclusive culture and healthy work life balance include hybrid working, Sport & Social Clubs and Diversity and Inclusion networks.

As an employee of SMBC you have access to a host of both useful and exciting benefit offerings. See below some of the benefits on offer to you:

• Hybrid and flexible working 
• Competitive paid leave days
• Benefits to support your physical wellbeing, including private medical insurance and life and invalidity insurance 
• Various policies to support your mental wellbeing, including a robust behavioural health network with counselling and coaching services  
• Access a wide range of learning and development opportunities and career progression opportunities 
• Ambitious remuneration package

So, if you like a challenge and want to continuously grow and develop in a role where you will be supported along the way by a dynamic and diverse team, apply today!!