Deputy MLRO - Sanctions, Controls & Monitoring
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.
Within UKFS, the DMLRO SCM will:
• Manage UKFS personnel on: 1. Controls & Monitoring; and 2. Sanctions and Transaction Monitoring Alerts.
• 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 sanctions and transaction monitoring expertise, to ensure appropriate delivery of tailored advice on UK issues (including AML, Terrorist Financing and Sanctions), as well as co-ordinating inter-BNPP liaison on EU, US (OFAC) and other international financial sanctions requirements.
• Deliver a risk-based Controls and Monitoring Plan, liaising, as necessary, with the MLRO, Nominated Officer and colleagues in Compliance and Operational Risk & Permanent Control and Inspection General.
• Ensure Monitoring and Control considers all aspects of Financial Crime, and reporting of findings includes preparation and presentation of risk-based plans (and review outcomes) to the UK AML Committee, or senior management.
• Lead on preparation and delivery of regular and ad-hoc management information.
• Advise staff on interpretation of applicable financial crime policy and procedure, to assist staff members comply with regulatory requirements and internal policies with regards to anti-money laundering, anti-bribery and sanctions.
• Provide “4 eye” oversight, to quality assure UKFS delivery.
The DMLRO SCM will be specifically responsible for the oversight of:
Payments and transaction/sanctions risk
• List management: To update applicable lists (e.g. Vigilance) ensuring HMT sanctioned entities are included on the Group Consolidated list.
• Customer and Transaction Screening - Sanctions:
o To oversee the approval / rejection / blocking of real-time Customer / bank transactions through bank screening mechanisms, whilst ensuring maintenance of a robust audit trail and documented rationale of all decisions made.
o Ensure “4 eye” oversight process is maintained at all times regardless of alert.
o To cascade any “real” sanctions alerts to appropriate areas.
Sanctions and PEPs
• To review / decide / escalate as appropriate PEP and sanctions referrals alerted on BNPP Customer data.
• Ensure relevant hits are escalated to the DD / UKFS – EDD Function.
• To oversee the review, escalation and/or closure of AML alerts generated by bank systems (e.g. AMLS, Actimize CM, Actimize CIB); and ensuring maintenance of a robust audit trail and documented rationale of all decisions made.
• Review rules and settings and suggest changes where necessary (annual basis or Ad hoc).
• Ensure “4 eye” oversight process is maintained at all times regardless of alert.
• To ensure Management is made aware of all pressing issues in a timely fashion
• To operate to the very highest level of integrity at all times.
SAR Investigation and internal reporting:
• Report to the Nominated Officer/Investigations team, any knowledge or suspicion of money laundering or terrorist financing, via the approved SAR process.
Other – Sanctions and AML Risk
• Manage BNPP US Recusal Process including the provision of appropriate training to relevant persons.
• Report any breaches of legislation or bank policy using the banks breach reporting procedure and escalate issue to the appropriate area.
• Ensure annual and ad-hoc training is reviewed and updated (as necessary), to reflect UK regulatory and BNPP internal policy requirements.
• Maintain accurate records and ensure delivery of high quality Management Information.
• Ensure detailed review of sanctions-related matters referred to the UKFS and be ready to respond on urgent issues, including risk assessment and mitigates to inform management consideration of identifiable risk.
• Ensure timely review and assessment of policy and procedure against UK regulatory requirements and UK good practice guidance (per JMLSG).
Controls and Monitoring:
• Assist the MLRO in compilation of the annual MLRO Report.
• Assist the MLRO to prepare Monthly AML Committee reporting.
• Maintain MI in a central repository.
• Undertake (and support delivery of) the annual FCP Risk assessment and devise the AML Control Plan – detailing the second level controls to be undertaken by the Controls team.
• Ensure production of accurate and meaningful MI for use in the relevant committees and to inform the MLRO of Financial Crime risks within the business.
• Deputise as Chair for the AML Committee where required.
• Complete periodic Head Office returns advising of the effectiveness of controls.
• Strong track record in managing a team on the assessment and response to Money Laundering and sanctions risk; and making decisions to mitigate risk / escalate accordingly.
• Good working knowledge of UK, EU and US sanctions regimes and an understanding of other regimes.
• 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 bribery 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
• Strong analytical skills
• Able to communicate and gain the respect of all levels of management and staff
• Detailed knowledge of UK Money Laundering Regulations, FCA rules and JMLSG Guidance Notes
• Detailed knowledge of UK, EU, OFAC and other relevant sanctions regimes
• Detailed knowledge of anti-bribery and corruption regimes in UK and US
• Appreciation of the mechanics and workings of the UK law enforcement agencies and courts
• Strong administrative skills
• Strong presentation skills
• IT skills (Word, Excel & PowerPoint)
• French language knowledge would be of benefit