BNP Paribas is a leading bank in Europe with an international reach. It has a presence in 73 countries, with more than 196,000 employees, including around 149,000 in Europe. The Group has key positions in its three main activities: Domestic Markets, International Financial Services (whose retail-banking networks and financial services are covered by Retail Banking & Services) and Corporate & Institutional Banking, which serves two client franchises: corporate clients and institutional investors.
BNP Paribas Corporate and Institutional Banking is a globally recognised leader offering capital markets, securities services, financing, treasury and advisory solutions.
Business Area / Deparment Overview
The UK Financial Security team (UKFS) has oversight responsibilities for areas including anti-money laundering, fraud, bribery, sanctions, PEPs and high risk clients. The UK Financial Security team reports to the UK MLRO. The team members require a significant degree of ‘self-starting’. The Financial Security Compliance Officer 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
- Reviewing adequacy and completeness of customer due diligence completed by the Due Diligence Team (‘DDT’) on new-to-bank and recertified (existing) clients, particularly for compliance with applicable Policy and UK regulatory requirements
- Risk assessment for high risk escalations, including Money Laundering, Sanctions, Bribery, corruption and internal failings.
- Interpreting and advising BNP Paribas CIB London staff on applicable laws, regulations and standards.
- Training staff on relevant regulations and standards.
- Monitoring and reporting on compliance with applicable laws, regulations and standards • Investigating and reporting on any suspected breach of applicable standards
Purpose & Scope of Role
Providing technical FS compliance advice across UK CIB business areas, on high risk/complex financial crime related topics, regulatory issues and industry changes. Assisting the business to comply with group Policies and UK regulatory requirements (i.e. with regards to anti-money laundering, financial sanctions and broader financial crime issues) and standards.
Scope: UK – CIB incl. BNP Paribas Securities Services London Branch
Key Responsibilities of Role
This role will be specifically responsible for:
High Risk Escalations:
- To review PEP and other higher-risk referrals (e.g. from the London Due Diligence Team, CIB business areas in London or internationally), to assess financial crime risks and agree appropriate level of risk for each referral. To ensure all relevant records are updated and maintained accordingly, to ensure appropriate audit-trails for decisions.
- Review contract and deal specific documentation to asses for the presence of financial crime compliance risk (e.g. sanctions, bribery, money laundering, etc.), to identify options to mitigate identifiable risk (in consultation with other specialists – e.g. Legal).
- Represent UKFS in Client Acceptance Committees, New Activity Committees and other internal forums related to higher-risk clients, products and risk in the operating/business environment.
- Provide advice consistent with (and ensuring appropriate application of) Group policies and applicable legal and regulatory requirements, particularly in relation to anti-money laundering (‘AML) and financial sanctions, anti-bribery, and related AML or Financial Crime policies and procedure.
- Maintain up-to-date awareness and understanding of UK requirements, particularly in relation to Money Laundering Regulations (or equivalent), Financial Sanctions (e.g. UK, France, EU and US OFAC) and FCA Handbook (in relation Financial Crime) and FCA Financial Crime Guidance (i.e. ‘core knowledge’).
- Applying understanding of core knowledge when supporting/advising CIB business areas and support functions.
- Competently demonstrate key AML analysis and articulate clear guidance to inform opinion on how best to identify and respond to financial crime risk, including, inter-alia, via formal reporting to the AML Committee and/or a senior business forum.
Leadership and Management:
- To lead and manage regulatory and other projects as requested with a high degree of autonomy.
- To manage people (direct supervision) related to remediation/other specific projects as directed
- To attend senior committees and working groups as UKFS delegate where directed
- Representing UKFS on global strategic projects.
Policy & Procedures:
- To provide specific support to the Policy Development Lead and Advisory Manager in the review, drafting and implementation of existing and new policy (+ related) documentation.
Training and Guidance:
- Support CIB development and delivery (where necessary) of financial crime training.
- Key compliance contact for the business, particularly in relation to core knowledge areas.
SAR Investigation and internal reporting:
- Report to the Nominated Officer / Investigations team any knowledge or suspicion of money laundering or terrorist financing using the bank’s internal SAR escalation process.
- Ensure up-to-date awareness and application of other internal reporting requirements covered by Group Policy and UK Law / Regulation (with regards to financial crime).
- Report any breaches of legislation or bank policy using the bank’s breach reporting procedure and escalate issue to the appropriate area.
- Provide expertise and support relating to complex financial crime related investigations as required.
Other (Ad hoc):
- Maintain highly accurate records and to ensure any Management Information produced is of the highest standard.
- Ensure Management is made aware of all pressing issues in a timely fashion.
- Provide support to regular and ad-hoc internal CIB projects which require subject matter specialist input and advice/guidance (re financial crime).
- Ensure appropriate audit trail for all advice / key decisions
- Provide support and training to more junior members of the team as required by line management
Experience, Qualifications & Competencies
- Significant prior experience working in a financial crime advisory environment – including AML (not solely Customer Due Diligence), Financial Sanctions and/or anti-bribery systems and controls in a UK FCA regulated firm (preferably a CIB environment).
- Strong track record in assessing AML risk/cases and making (and documenting) informed decisions to mitigate AML risk / escalate accordingly.
- A strong working knowledge of UK, EU and US sanctions regimes and an understanding of other regimes.
- An advanced and broad understanding of general AML risk issues in a CIB environment, such as, IB product, intra-jurisdictional AML and sanctions risk and client-type risk.
- An advanced knowledge of products/services and 1st line operations across CIB and BPSS business areas.
- An advanced understanding of other financial crime risk, such as, bribery and fraud.
- A detailed working knowledge of current UK regulatory environment for financial crime is essential and an understanding of future proposed changes would be desirable.
- The ability to apply a holistic approach to identifying, investigating and mitigating financial crime risk, and the ability to consider a range of risk mitigants, to present a balanced opinion of key issues to line Management.
- Excellent team player within a high pressure environment
- First class communication skills, both written and oral
- A proven ability to present a given issue to Senior Management, both within the 1st and 2nd line, and argue a case accordingly
- A self-starter who requires minimal supervision
- A proactive approach to all aspects of the role will be essential
- A proven ability to make quick (but informed and rational) decisions whilst ensuring that issues/risk have been appropriately considered and mitigated
- Experience in financial crime investigations (both internal and external).
- Strong track record in assessing AB&C related cases and making (and documenting) informed decisions to mitigate AB&C and CCO risk/escalate accordingly