Deputy MLRO - Anti-Bribery & Corruption and Policy & Procedures
Standard / Permanent
COMPLIANCE AND PERMANENT CONTROL
The UK Financial Security Team (UKFS) has oversight responsibilities for areas including anti-money laundering, fraud, bribery, sanctions, PEPs and high risk clients. The UKFS team reports to the UK MLRO. The team members require a significant degree of ‘self-starting’. The DMLRO SCM performs a number of functions, which include:
• Supporting and assisting senior management in adherence to applicable laws and regulations as well as to high standards of business and ethical integrity.
• Interpreting and advising BNP Paribas CIB London staff on applicable laws, regulations and standards.
• Providing training where appropriate to staff on a number of relevant laws, regulations and standards.
• Monitoring and reporting on BNP Paribas CIB London and staff compliance with laws, regulations and standards.
• Investigating and reporting on any suspected breaches of such laws, regulations and standards.
• Implementing the control framework for an effective anti-bribery and corruption programme for the UK CIB environment
• Responsible for the composition, coordination and maintenance of the UK specific policies and procedures across the BNP Paribas CIB London branch.
Within UKFS, the DMLRO will:
• Manage UKFS personnel on: Programme Management.
• Support the MLRO and deputise where required; as well as operational cover/support to UKFS/DMLRO colleagues (e.g. holiday cover, support UKFS workflow response, etc.).
• Provide AB&C expertise, to ensure appropriate delivery of tailored advice on UK issues as well as co-ordinating inter-BNPP liaison on EU, US (FCPA) and other international Bribery and Corruption requirements.
• Deliver a risk-based AB&C control programme, liaising, as necessary, with the MLRO, Nominated Officer and colleagues in Compliance and Operational Risk & Permanent Control and Inspection General.
• Oversight of UKFS Governance and coordination of UKFS financial security programme
• Coordination of UKFS Policies & Procedures, including UK supplements
• UK Territories Liaison Oversight of territories coordination and relationships
The DMLRO will be specifically responsible for the oversight of:
Anti-Bribery and Corruption Risk
• Programme Management: Principle oversight of the AB&C within the BNP Paribas CIB London branch and coordination across UK territories. Ensuring there is an effective programme in place and that the controls are appropriate and effective.
• Management Information& Reporting:
o To design and develop appropriate MI relating to the oversight of the AB&C programme.
o Present the relevant MI to relevant committees and board meetings and through regularly monthly reporting.
Policy and Procedures
o Ensure the UK AB&C policy and procedures are fit for purpose and reviewed on a regular basis.
o Oversee the design, development and delivery of all AB&C related training.
• SAR Investigation and internal reporting:
o Report to the Nominated Officer/Investigations team, any knowledge or suspicion of money laundering or terrorist financing, via the approved SAR process.
Policies and Procedures
• Oversight and coordination of all UKFS Policies and Procedures, including the development of UK supplements where required. Gap analysis of Group policies against UK legislative and regulatory requirements.
UKFS Governance and coordination of UKFS programme
• Ensure there is suitable and appropriate Management Information which contains KPIs and KRIs with appropriate escalation of identified issues.
• Oversight of all actionable items (Audit, Compliance or Regulatory), ensuring that items do not fall overdue.
• Ensure the monthly UKFS Oversight Committee pack is produced and attendance at the meeting.
UK Territories Liaison Oversight of territories coordination and relationships
• Ensure there is suitable and appropriate Management Information which contains KPIs and KRIs
• Establish strong stakeholder relationships with each UK business, to better understand their Financial Crime risks. Development of an appropriate UK territories dashboard.
• Good working knowledge of UK, EU and US Bribery laws and an understanding of other regimes.
• Experience in drafting and maintaining Policies and Procedures
• Broad understanding of general AML risk issues such as product, jurisdiction and client-type risk.
• An understanding of other financial crime risk issues such as AML, Sanctions and fraud is preferable.
• Detailed working knowledge of UK regulator’s financial crime guidance is essential and an understanding of future proposed changes would be desirable.
• Ability to apply holistic approach to identifying, investigating and mitigating financial crime risk, and presenting a balanced view/opinion of issues to line Management.
• Excellent team player within a high pressure environment.
• First class communication skills, both written and oral.
• Proven ability to present a given issue to Management and argue a case accordingly.
• Self-starter who requires minimal supervision.
• Proactive approach to all aspects of the role will be essential.
• Proven ability to make quick decisions whilst also ensuring that all issues have been appropriately considered and mitigated