RESPONSIBILITIESStrategy
• Input to Group/Region/Country/Client Business operating model design of relevant FCC and business processes.• Ensure that there is adequate support (people, processes, tools, frameworks, systems) in Egypt for necessary FCC controls.• Set and implement the vision, strategy, direction and leadership for Egypt, consistent with the vision and strategy for FCC and in support of the Group’s strategic direction and growth aspirations.
Business*
• Analyse comprehensive impact of financial crime related regulatory matters on the relevants business area and its operations.• Ensure that key changes (to laws, rules, regulations) are communicated and cascaded (in region/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 resolution of competing requirements between regulations, for example between AML regulations and data privacy/bank secrecy or information security regulations.• Manage all related FCC advisory for countries within the cluster and escalate to the FCC Cluster Head and FCC Regional and & Product Heads where necessary.
Key ResponsibilitiesProcesses
• Providing support to the Compliance function in Egypt and providing the Management with confidence that businesses and functions are operating within prevailing laws, regulations and operational risk tolerances, that operational risk management practice is consistent with Group Standards, and that associated control effort is proportionate to risk.• To provide independent assurance of compliance to internal and external obligations through Compliance Monitoring Reviews.• Establish and maintain frameworks within Egypt to ensure compliance with applicable banking regulations, internal policies, standards and codes so as to protect the reputation of the bank with its regulators and balance the needs of other stakeholders.• 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.• Providing governance and oversight over the implementation of FCC-related policies and Standards in Egypt to ensure compliance with such policies and Standards.• 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/Fraud].• Act 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 Fraud, and escalate issues as appropriate.
Skills and Experience
Risk Management
• Maintain oversight of risk mitigating action plans.• Ensure the suitability and quality of case data maintained on enterprise case management systems.• Understand technical aspects of systems relevant to CDD, Client Risk Assessments, Name and Transaction Screening, AML Monitoring and Case Management.• Ensure that detection scenarios that are developed and deployed are fit-for-purpose.• Establish and maintain watch lists used for customer and transaction screening and various other due diligence and investigative purposes (local/regional internal and external).• Provide advice on the application of risk management frameworks• Apply Group and FCC policies and processes to manage risks.• 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.• Inform senior management and relevant regulators of serious regulatory breaches (or where risk tolerances have been breached) and ensure that actions are taken quickly to remediate and/or activities are ceased.• Anticipate horizon risks in the area of financial crime that may have a significant impact on the Group and develop effective strategies to mitigate such horizon risks.• Identify intelligence for typology studies and risk mitigation plans.• Conduct Country risk assessment.• Map risks, quantify the potential impact and escalate where necessary.• Advise relevant stakeholders on outcomes of risks identification and assessment methodologies.• Deliver/ support delivery of annual Global AML, ABC and Sanctions Risk Assessments.• Partner with legal counsels for advice on technical matters.• Conduct a root cause analysis on the control/other failures to ensure lessons are learned across the bank.• Provide intelligence (to internal forums) on specific clients, client-types and emerging risk typologies.• Provide intelligence inputs to support calibration of bank’s Risk Methodologies (including aggregate client risk, product risk and country risk assessments).• Oversee the review and analysis of the client base to identify and manage high risk clients, or specific country reviews.
QualificationsGovernance
• Attend relevant leadership meetings.• Provide [or support] senior oversight of FCC region/country/function.• Ensure tracking and remediation of surveillance and investigations related regulatory findings.• In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure senior management and relevant regulators are informed and that actions are taken quickly to remediate and/or activities are ceased.• Prepare and cascade lessons learned from audit findings, FCC assurance activities and specific investigations.• Track significant issues arising from FCC metrics, FCC Assurance activities, Audit reviews and regulatory inspections, providing validation of issue closure where necessary.• Propose control improvements, enhancements and simplifications where appropriate.• Be accountable for identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.• Collate, analyse and interpret data in reports to senior management and relevant governance/risk committees.• 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.
Project/Change Management
• Lead or influence significant programmes of work in support of the financial crime compliance objectives.• Review new business requirements and provide solutions where required.• Provide skilled resources to support project/programme delivery.• 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.
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