Job Title: Assistant Vice President – Quality Assurance (AML)
Department: ISPL CEFS AML Operations
About Business line/Function:
CEFS team is leveraging an integrated model; the Team delivers a comprehensive range of solutions to various business lines of the Group across the globe. The services include referential data management, Know Your Customer (KYC), Due Diligence preparation (client recertification and onboarding), credit administration and post-trade client services, AML transaction monitoring and Actimize support Projects.
Position Purpose:
An Assistant Vice President (AVP) for Quality Assurance (QA) within the Anti-Money Laundering (AML) domain occupies a middle-management role. They act as a critical line of defense, ensuring that the processes used to detect, prevent, and report money laun dering and terrorist financing are effective, compliant, and operating according to regulatory standards.
Responsibilities
1. Alert Disposition & Investigation Validation
• Decision Accuracy Review: Auditing a sample of "Closed/No Suspicion" alerts to ensure that investigators have provided sufficient rationale and that the activity truly does not warrant an escalation.
• Investigation Quality Assessment: Evaluating the depth of the "investigative trail"—ensuring investigators have looked beyond the single alert to review the client’s historical behavior, source of wealth, and related party transactions.
• Narrative & Documentation Audit: Verifying that the written rationales in the Case Management System (CMS) are clear, logical, and would stand up to scrutiny from a regulator or internal auditor.
• Red Flag Identification: Ensuring that specific typologies (e.g., structuring, smurfing, rapid movement of funds, or unusual geographic activity) were correctly identified and addressed during the investigation.
2. Detection Logic & System Effectiveness (The "Second Line" view)
• Threshold & Scenario Testing: Partnering with the TM Tuning team to validate whether current detection scenarios (rules) are effective or if they are producing excessive false positives/missed true positives.
• False Positive Analysis: Analyzing trends in "false positives" to identify if specific rules require recalibration or if they are no longer capturing relevant risk.
• Model Validation Support: Providing QA insights during the periodic review of the Transaction Monitoring System (TMS) to ensure the mathematical logic of the alerts aligns with the bank's risk appetite.
3. Regulatory Reporting (SAR/STR) Oversight
• Reporting Quality Assurance: Performing a final check on Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) to ensure the "Who, What, Where, When, and Why" is clearly articulated.
• Timeliness Monitoring: Ensuring that the time elapsed from the initial alert trigger to the final regulatory filing meets the statutory deadlines (e.g., the "30-day rule").
• Escalation Integrity: Verifying that all alerts that met the threshold for "suspicion" were actually escalated to the SAR filing stage and not inappropriately dismissed.
4. Risk-Based QA Strategy & Metrics
• Risk-Based Sampling Design: Instead of random sampling, designing a QA program that prioritizes high-risk segments (e.g., PEPs, high-risk jurisdictions, or correspondent banking) for deeper scrutiny.
• Error Trend Analysis: Categorizing errors (e.g., "failure to identify source of funds," "insufficient profile review," or "incorrect data entry") to identify systemic training gaps.
• KPI/KRI Development: Defining and tracking specific Key Quality Indicators (KQIs) such as:
• Error Rate per Investigator.
• Percentage of overturned decisions (where QA disagrees with the Investigator).
• Average age of open alerts (Backlog Management).
5. Stakeholder & Remediation Management
• Feedback Loop Management: Implementing a formal process to provide "Return to Investigator" (RTI) feedback, ensuring that errors are corrected and lessons are learned.
• Remediation Oversight: Leading the QA effort during "look-back" projects (remediation exercises) where a systemic failure requires the re-review of months or years of transaction data.
• Audit Liaison: Acting as the subject matter expert (SME) for Transaction Monitoring when interviewed by Internal Audit or external regulators regarding the effectiveness of the monitoring program.
6. People
· Provide leadership and direction to the CEFS department and its employees, set conditions and manage its resources in order to optimize departmental services for maximum fulfillment of (internal and external) client needs within determined strategy and budget.
· Work with ISPL CLM Operations sub-departments to develop a strong expertise & knowledge on end to end process / delivery. Coach & mentor top talent and define clear career path for them
· Promote, within ISPL Client Engagement Operations department, a mindset around accountability, continuous improvement, client focus, change management & innovation
· Proven aptitude to lead and manage high performing teams
· Team Attrition & Engagement: Maintaining high employee morale and managing turnover within the monitoring team.
Technical & Behavioral Competencies
· Proficiency in MS Office and VBA Macros.
· Rapid adaptability to new systems.
· Strong technical aptitude.
· Commitment to continuous technological learning.
· Logical problem-solving capabilities.
· Ability to work autonomously and collaborate with global teams.
· Exceptional interpersonal and communication skills.
· Decisive leadership on complex business and technical issues.
· Preferred experience in banking, payments, or compliance.
Specific Qualifications:
• Minimum 10-14 years of experience along with Bachelor's Degree - in management, finance, science, economics, related field or equivalent experience.
• Prior experience in similar domain.
Skills Referential (Required knowledge, skills and abilities)
· Collaborative teamwork.
· Strong oral and written communication.
· Ability to synthesize and simplify information.
· Strong organizational skills.
Transversal Skills:
· Strong analytical skills.
· Process development and adaptation.
· Project management proficiency.
· Meeting, seminar, committee, and training facilitation.
Key Performance Indicators & Collaboration for the Role:
· Departmental SLA Compliance: The percentage of total team alerts and investigations completed within regulatory or internal timelines.
· Resource Utilization & Capacity Planning: Efficiency in managing headcount against alert volumes (ensuring the team is neither over-burdened nor under-utilized).
· Backlog Management: Ability to control and reduce the volume of aged/overdue alerts to prevent regulatory breaches.
· Cost Per Alert/Investigation: Managing the operational budget by optimizing the cost of processing a single alert (balancing headcount vs. automation).
· Talent Development: Success in upskilling Associates into Seniors and Seniors into Leads (succession planning).
· Audit & Regulatory Exam Performance: The ability to defend the department's processes and findings during internal audits or external regulatory examinations.
· IT & Product Management: Partnering with technical teams to drive system upgrades, rule tuning, and the implementation of automation/AI tools.
· Cross-Functional Project Leadership: Leading multi-departmental task forces for large-scale system migrations or regulatory remediation projects.
· Representing CEFS ISPL locally and globally in all required forums, decision making and execution at ground level.
Direct Report to: Vice President (VP)
Education Level: Bachelor Degree or equivalent
Location: Mumbai
About BNP Paribas Group:
BNP Paribas is the European Union’s leading bank and key player in international banking. It operates in 65 countries and has nearly 185,000 employees, including more than 145,000 in Europe. The Group has key positions in its three main fields of activity: Commercial, Personal Banking & Services for the Group’s commercial & personal banking and several specialized businesses including BNP Paribas Personal Finance and Arval; Investment & Protection Services for savings, investment, and protection solutions; and Corporate & Institutional Banking, focused on corporate and institutional clients. Based on its strong diversified and integrated model, the Group helps all its clients (individuals, community associations, entrepreneurs, SMEs, corporates and institutional clients) to realize their projects through solutions spanning financing, investment, savings and protection insurance. In Europe, BNP Paribas has four domestic markets: Belgium, France, Italy, and Luxembourg. The Group is rolling out its integrated commercial & personal banking model across several Mediterranean countries, Turkey, and Eastern Europe. As a key player in international banking, the Group has leading platforms and business lines in Europe, a strong presence in the Americas as well as a solid and fast-growing business in Asia-Pacific. BNP Paribas has implemented a Corporate Social Responsibility approach in all its activities, enabling it to contribute to the construction of a sustainable future, while ensuring the Group's performance and stability.
About BNP Paribas India Solutions:
Established in 2005, BNP Paribas India Solutions is a wholly owned subsidiary of BNP Paribas SA, European Union’s leading bank with an international reach. With delivery centers located in Bengaluru, Chennai and Mumbai, we are a 24x7 global delivery center. India Solutions services three business lines: Corporate and Institutional Banking, Investment Solutions and Retail Banking for BNP Paribas across the Group. Driving innovation and growth, we are harnessing the potential of over 10000 employees, to provide support and develop best-in-class solutions.
Commitment to Diversity and Inclusion
At BNP Paribas, we passionately embrace diversity and are committed to fostering an inclusive workplace where all employees are valued, respected and can bring their authentic selves to work. We prohibit Discrimination and Harassment of any kind and our policies promote equal employment opportunity for all employees and applicants, irrespective of, but not limited to their gender, gender identity, sex, sexual orientation, ethnicity, race, colour, national origin, age, religion, social status, mental or physical disabilities, veteran status etc. As a global Bank, we truly believe that inclusion and diversity of our teams is key to our success in serving our clients and the communities we operate in. As a global Bank, we truly believe that inclusion and diversity of our teams is key to our success in serving our clients and the communities we operate in.
