PERM - CPD - Head of Financial Crime Compliance - Executive Director

Section 2 – Purpose of Job

• To provide advice and guidance to the London business and support functions as well as EMEA Local office MLROs on financial crime compliance matters.
• To provide advice and guidance on the regulatory and legal expectations with respect to financial crime compliance.
• To provide advice and guidance on the design and operation of financial crime systems and controls, by which the EMEA region interdicts and mitigates financial crime risk.
• Management of Financial Crime service provision to EMEA offices.
• To support the RCCO and regional MLROs to develop the regional financial crime strategy.
• To undertake the role of Nominated Officer for SMBC BI and SMBC London Branch.

Section 3 – Background

• As a regulated financial institution, the Bank has an obligation to establish and maintain policies, procedures, systems and controls to mitigate and effectively manage the financial crime risk. The Bank has operations across the EMEA region and is required to consider extraterritorial laws, and accordingly must maintain a coordinated and aligned approach to the framework taking this into account.

• The role holder covers all financial crime taxonomies excluding Sanctions and has a multi-disciplinary remit, covering various business areas and geographies.
• The role holder is required to have close collaboration with the Regional Chief Compliance Officer, Chief Operating Officer, Chief Risk Officer and other Senior Management, Executive/Local Management Committee members, Local Compliance Officers, Money Laundering Reporting Officers, Chief Representative Officers, Head Office Compliance, PD-ITSD and Internal Audit.
• The role-holder is responsible for reviewing highly sensitive and confidential information.
• The role holder will work jointly with the EMEA Head of Sanctions to deliver a joint approach to investigation and intelligence gathering and the subsequent dissemination.

The role holder will:

• Act as a point of contact to receive internal Suspicious Activity Reports. Take appropriate action following the receipt of an internal Suspicious Activity Report in accordance with relevant laws, regulations and polices. To determine and document whether a Suspicious Activity Report is required to be made to the relevant authorities.

• Identify where there is an impact to other areas of SMBC, communicating and acting as appropriate.
• Be the subject matter expert on financial crime related matters (excluding KYC and Sanctions) and act in an advisory capacity within the second line of defence.
• Further develop and enhance the Financial Crime Compliance framework, including enterprise wide fraud risk. Ensure the Financial Crime framework remains fit for purpose in according with regulatory expectations including acting upon new and emerging threats/risks, findings (both internal and external) etc.  Make recommendations for, and where appropriate implement  improvements to the financial crime systems and controls,
• Implement and oversee the delivery and adherence to wider financial crime training.
• To act as the point of contact for the authorities and the regulators regarding money laundering and financial crime issues.

Section 4 – Facts / Scale

• Number of reports/team members: Currently 12
• Main interfaces/relationships: All Financial Crime Groups across EMEA including all MLRO’s. Regular interface with the Regional Chief Compliance Officer, Chief Operating Officer, Chief Risk Officer and other Senior Management, Executive/Local Management Committee members, Local Compliance Officers, Money Laundering Reporting Officers, Chief Representative Officers, Head Office Compliance, PD-ITSD and Internal Audit.
• Role holder to provide advice, guidance and support to all the EMEA offices and financial crime teams relating to financial crime compliance matters.
• Monitor UK regulatory and legislative changes ensuring necessary communication and change implementation as required across the EMEA region.
• Have the oversight and coordination of significant financial crime investigations, collaborating on sanctions investigations as required. 
• Represent the Bank at external forums

Section 5 – Accountabilities & Responsibilities

• Analyse and interpret the financial crime regulations and laws across applicable financial crime risk taxonomies ensure compliance to enforce effective management, oversight and implementation of financial crime polices required to meet the legal and regulatory expectations.
• Responsible for relevant Financial Crime Policies and Procedures/Standards.
• Investigate and escalate breaches of financial crime controls (including employee breaches).
• Manage, review and implement recommendations from external / internal audits and risk assessments.
• Strengthen the Financial Crime  systems and controls function by continued review, development and enhancement of systems and policy / guidance in line with regulatory requirements and industry best practice.
• Identify and address any training needs across all departments within the 3 lines of defence framework. Co-ordinate and deliver training on relevant financial crime matters including new and existing systems and controls.

Develop and strengthen relationships with internal and external stakeholders to promote best practice and ensure a good understanding of financial crime requirements.

Section 6 – Knowledge, Skills, Experience & Qualifications

• Educated to degree level (with a relevant degree) and a professional qualification(s) in financial crime.
• Experience in implementing enterprise wide Financial Crime risk management frameworks
• Expertise in Financial Crime risk taxonomies including Fraud, AML and CTF including associated investigations.
• Fully conversant with, and working knowledge of, industry practice and tools used to combat fraud, money laundering, terrorist financing and other areas of financial crime.
• Able to provide specific and targeted advice and guidance, subject matter expertise, and to liaise with other stakeholders to ensure effective working relationships are built and maintained.
• Ability to work well under pressure ensuring all deadlines are met, whilst maintaining excellent attention to detail at all times.
• Thorough experience of dealing with financial crime at an international level.
• Experienced decision maker, with the ability to influence and motivate at all levels.
• Excellent written and verbal skills.
• Experienced in formal report writing that can be used to communicate investigative reports, policies, procedures, processes and training to a wide-ranging audience whilst being adaptive to needs on a case by case basis.
• Ability initiate and implement changes to improve efficiency.
• Ability to collaborate effectively and work with others to drive change.