UK Financial Security Compliance Officer - FSCO
Business Area Overview
BNP Paribas has a presence in 75 countries with more than 185,000 employees, including 145,000 in Europe. It ranks highly in its two core activities: Retail Banking & Services and Corporate & Institutional Banking (CIB). BNP Paribas CIB is a leading European investment bank with global leadership in many of our businesses. With nearly 20,000 employees in over 45 countries, CIB can offer you an exciting and truly global career.
In the UK specifically there is a substantial presence in Corporate Banking and Capital Markets activities and the UK has aggressive growth plans over the next 5 years which reflects the Group’s commitment to remaining in the UK post-Brexit and developing a stronger presence here.
At BNP Paribas CIB, we work continuously on behalf of our clients, helping them to realize their projects around the world. You can be an important part of this, helping us to serve our clients both in mature and emerging markets, providing them with financial solutions across a diverse range of expertise, products and services. Our origins lie in Europe, but nearly a quarter of our employees now work in our multi-award-winning Asia Pacific offices and we are a committed player in all markets.
Strong risk management, combined with the stability that comes from being part of one of the largest banking groups in the world, underpin our success. Joining us, you’ll become an integral part of a dynamic team that spans nationalities, cultures and backgrounds, drawing together people from around the globe and reflecting our commitment to international placements.
The UK Financial Security Compliance Team (UKFS), led by the UK Head of Financial Security (MLRO, also holding personal liability as “SMF17” under the UK Regulatory regime) provides leadership and direction for the UK businesses in matters including Anti-Money Laundering (including KYC/DD, PEPs and other High Risk clients), Sanctions, Investigations and Bribery & Corruption. Financial Crime Policies are set at BNP Paribas Group level and the various technologies used for screening and transaction monitoring are owned in Paris Head Office but UKFS plays a key role not only in supporting the technical content of Group policies and technologies but also in ensuring across the UK the appropriate implementation of Polices and compliance with UK legislation and regulatory requirements.
UKFS team members require a significant degree of ‘self-starting’, to support 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 UK staff on applicable laws, regulations and standards, particularly with regard to KYC/Due Diligence and Sanctions requirements.
• Providing training where appropriate to staff on a number of relevant laws, regulations and standards.
• Monitoring and reporting on BNP Paribas CIB UK and staff compliance with laws, regulations and standards. This work includes undertaking oversight testing and assurance reviews of a number of processes both in the UK and in the “near-shored” CIB EMEA Competency Centre in Lisbon.
• Investigating and reporting on any suspected breaches of such laws, regulations and standards.
Overall Job Purpose
Within Compliance the FSCO will support:
• Development, implementation, maintenance and execution of Financial Security Second Line of Defense controls in line with the Group and local requirements
• Development and execution of the Financial Security monitoring reviews & assessments
• Ensuring that issues identified are dealt with in a timely manner and receive sufficient business focus
• Reporting and participating in other projects and initiatives as required and as part of ongoing career and technical development.
The FSCO will be specifically responsible for:
• Performing controls and reviews across all applicable Financial Security related areas (e.g. KYC, sanctions, ABC, ML etc.) within CIB UK and territorial entities to provide reasonable assurance to the Management that there are adequate controls in place to manage financial crime risks. Such controls and reviews will be carried out in accordance with the Group Controls Programme and the agreed UK Compliance Assurance Programme.
• Providing suitable challenge to the business and functions with regards to financial crime risk
• Making appropriate suggestion for enhancements of controls, processes and procedures where relevant
• Testing application and effectiveness of financial crime policies and procedures (by undertaking compliance assurance testing as defined in the control and monitoring plan) across CIB business and functions
• Testing of data feeds, models, scenarios and algorithms in FS systems and other technology
• Testing of activities which have been “near-shored” from London, primarily to BNPP Lisbon but also other locations as needed;
• Maintaining appropriate records and work papers detailing the review work undertaken
• Preparation of control and review reports outlining key findings and agreed remediating actions
• Ensuring that issues identified are dealt with in a timely manner and receive sufficient focus
• Supporting Financial Security Risk Assessment
• Supporting development, implementation and execution of FS Assurance Plan
• Identifying any relevant Financial Security risks highlighted by the regulators including their thematic work and by organizations such as FATF, NCA, FCA or TI, which may have potential impact on the operation of the business lines, functions, 2LOD controls, monitoring reviews and processes
• MI reporting and participation in other projects and initiatives
• Proven experience working in a financial crime environment, preferably in an investment banking context performing monitoring controls and reviews
• Experience with preparing management information on financial crime such as money laundering (ML) and terrorist financing (TF) risk (or related data) to inform senior management decision making (i.e. to mitigate AML risk / escalate accordingly).
• Good working knowledge of the FCA’s Financial Crime Guide and of the UK Joint Money Laundering Steering Group (‘JMLSG’) Guidance.
• Good working knowledge of the UK AML, CTF and ABC regimes and an understanding of other regimes.
• Good analytical skills, with good Microsoft Excel and data analysis capability.
• Broad understanding of general AML risk associated with product, jurisdiction and client-type(s).
• An understanding of other financial crime risk issues such as bribery and fraud is preferable.
• Ability to apply holistic approach to identifying, investigating and mitigating financial crime risk and (to propose risk mitigates) when presenting an informed/balanced view of 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 Management 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 decisions whilst also ensuring that all issues have been appropriately considered and mitigated.