FCC Controls Officer - Standard Chartered Bank

We are a leading international bank focused on helping people and companies prosper across Asia, Africa and the Middle East.

To us, good performance is about much more than turning a profit.  It’s about showing how you embody our valued behaviours – do the right thing, better together and never settle – as well as our brand promise, Here for good.

We’re committed to promoting equality in the workplace and creating an inclusive and flexible culture – one where everyone can realise their full potential and make a positive contribution to our organisation. This in turn helps us to provide better support to our broad client base.

RESPONSIBILITIES: 

Generic Functions

Strategy (Responsibilities that are related to the development and implementation of a strategy):

• Input to Country/Client Business operating model design of relevant FCC and business processes.
• Support Country Head, FCC to ensure that there is adequate support (people, processes, tools, frameworks, systems) in the Country/Department for necessary FCC works.
• Support Country Head, FCC to set and implement the vision, strategy, direction and leadership for the Country/Department, consistent with the vision and strategy for FCC and in support of the Group’s strategic direction and growth aspirations.

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Business (Responsibilities related to the delivery of business and / or financial objectives) :

• Support Country Head, FCC to analyse comprehensive impact of financial crime related regulatory matters on the relevants business area and its operations.
• Support Country Head, FCC to ensure that key changes (to laws, rules, regulations) are communicated and cascaded (in country), in coordination with group communications.
• 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 FCC.
• Support Country Head, FCC to resolve competing requirements between regulations, for example between AML regulations and data privacy/bank secrecy or information security regulations.

Core Functions:

• Automated and manual suspicious activity report investigation, review and submission to the local regulator.
• Management of the governance around suspicious activity reports, including maintenance of a log, and tracking of responses to the local regulator or authority.
• Generation and maintenance of suspicious activity report MI and analysis for reporting to the relevant governance committee and authorities.
• Responsibility for management of all Transaction Monitoring escalations from the Financial Crime Surveillance Unit (FCSU).
• Responsibility for management of all Name Screening alerts received from the FCSU hubs.
• Responsibility for ad hoc AML investigations work for SCB Ghana businesses.
• Management of FCC-related Court / Production / Freeze Orders received from regulators, authorities or the Group.
• Management of any cash threshold reporting or other obligations, including obligations around over-the-counter cash limits.
• Management of local first line testing, quality checks and quality assurance.
• Management of local watch lists.
• Liaise with Regional and Group FCSU, Regional Financial Crime Controls Compliance (RFCCC), Financial Crime Intelligence Investigations Unit (FCIIU) Teams and other relevant stakeholders.

Support Functions:

• Processes (Processes for which the role is responsible under the  ORF  as 1st & 2nd line; for executing / completing, and for supervising):
• Support the Country Head, FCC to develop, keep up to date and recommend for approval by the relevant Risk Committee, appropriate policies/processes/DOIs to address financial crime risks, aligning with relevant regulatory requirements.
• Support Country Head, FCC in providing governance and oversight over the implementation of FCC-related policies and procedures in Country to ensure compliance with such policies and procedures.
• Act as Process Owner for FCC-owned (sub-) processes under the Group’s Risk Management Framework, including implementation and roll-out of relevant processes and DOIs.
• Provide advice to relevant stakeholders on compliance with Group standards relating to (AML/Sanctions/ABC).
• Support Country Head, FCC to function as (second line) Risk Control Owner under the Group’s Risk Management Framework for those aspects of Regulatory Compliance relating to (AML/Sanctions/ABC), and escalate issues as appropriate.

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People and Talent (Responsibilities related to people and talent matters):

• Promote and embed a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm.
• Stimulate an environment where forward planning, prioritisation, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm.
• Support Country Head, FCC to deliver on the approved training curriculum for the year.

Risk Management (Responsibilities Under Risk Management  Framework – both execution and supervisory):

• Support Country Head, FCC to maintain oversight of risk mitigating action plans.
• Support Country Head, FCC to establish and maintain watch lists used for customer and transaction screening and various other due diligence and investigative purposes (local/regional internal and external).
• Support Country Head, FCC to provide advice on the application of risk management frameworks (e.g. ORF, GRA).
• Ensure to apply Group and FCC policies and processes (AML surveillance, client screening, risk assessment) to manage risks.
• Ensure to make recommendations (and/or implement) to relevant stakeholders on possible risk management responses to identified risks and/or findings of concerns from investigations.
• Assess risks arising from products / segments / geographies / customers / transactions and escalate any issues to Country Head, FCC.
• Inform Country Head, FCC/Head of Compliance of serious regulatory breaches (or where risk tolerances have been breached) and ensure support in the resolution of identified risk.
• Ensure to anticipate horizon risks in the area of financial crime that may have a significant impact on the business as a whole and assist to develop effective strategies to mitigate such horizon risks.
• Support Country Head FCC to conduct country risk assessment as and when prescribed by Group or local regulations.This may include delivery in all protocols (AML, ABC and Sanctions Risk Assessments).
• Support Country Head, FCC to oversee the review and analysis of the client base to identify and manage high risk clients, or specific country reviews.

Governance:

• Provide and support to business in addressing FCC related matters.
• Support in the tracking and remediation of FCC investigations related regulatory findings.
• In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure the Country Head, FCC and Head, Compliance are informed and support in actions are taken to quickly remediate the issues.
• Participate in the discussions of lessons learned from audit findings, FCC assurance activities and specific investigations and support in the implementation of same.
• Ensure to support the Country Head, FCC to track significant issues arising from FCC metrics, FCC Assurance activities, Audit reviews and regulatory inspections, providing validation of issue closure where necessary.
• Ensure to be accountable for identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.
• Ensure to support the Country Head, FCC to analyse and interpret data to produce reports that help the bank identify and manage emerging areas of risk / vulnerability and thus drive remediation action within the FCC function.

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Project/Change Management:

• Support the Country Head, FCC as accountable executive for key change in FCC related programmes in-country.
• Support significant programmes of work in support of the financial crime compliance objectives.
• Ensure to manage and protect business as usual (BAU) capability during change programmes, as well as during the execution and delivery of the remediation initiatives through project phase and into BAU.

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.
• Support Country FCC team to achieve the outcomes set out in the Bank’s Conduct Principles: Fair Outcomes for Clients; Effective Operation of Financial Markets; Financial Crime Prevention; The Right Environment.
• Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.
• Ensure to support in the implementation of directives of Bank of Ghana (BOG) / Financial Intelligence Centre (FIC) / Economic & Organised Crime Office (EOCO).

Key Stakeholders:

• Bank of Ghana (BOG)
• Financial Intelligence Centre (FIC)
• Economic & Organised Crime Office (EOCO)
• Compliance Officers Association of Ghana
• Local ACAMs Chapter, Ghana
• Other relevant industry stakeholders

Other Responsibilities:

• Embed “Here for Good” and Group’s brand and values in country.
• Perform other responsibilities assigned by Head, Compliance under Country or Functional policies and procedures.
• Multiple functions (double hats) as and when required (General Compliance Function)

Reports Directly to: Principal Associate, Financial Crime Compliance (Controls), Ghana