Payments Controls Officer (PCO), FCPT
Standard / Permanent
COMPLIANCE AND PERMANENT CONTROL
The London Financial Crime Prevention Team (FCPT) has oversight responsibilities for areas including anti-money laundering, fraud, bribery, sanctions, PEPs and high risk clients. The FCPT reports to the UK MLRO. The team members require a significant degree of ‘self-starting’. The PCO 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 Compliance, the FCPT Payment Controls Officer (‘PCO’) provides:
• Technical sanctions and transaction monitoring expertise.
• Policy compliant tailored advice in response to requests for guidance on AML/CFT issues.
• An easy to understand interpretation of policy, to assist BNPP personnel to comply with regulatory and BNPP requirements, regarding money laundering and financial sanctions.
• Support to the MLRO and Senior Controls officer, by ensuring appropriate application of second level controls over the review of payment alerts referred to the FCPT, or those generated via automated transaction monitoring and sanctions screening systems.
The Controls Officer will be specifically responsible for:
• To update relevant internal lists (e.g. Vigilance), ensuring that HMT sanctioned entities are included on the Group Consolidated list.
• Maintain up-to-date awareness of BNPP policy re financial sanctions, embargos and major sanctioned countries requirements (e.g. UK, EU and US OFAC requirements).
Customer and Transaction Screening:
• Review and approve / reject / block real-time Customer / bank transactions through the “Shine” or other mechanism (e.g. classifying alerts against requirements of BNPP Policy and UK, EU and US OFAC requirements).
• Ensure the “4 eye” process is maintained at all times regardless of alert type.
• Cascade any “real” sanctions alerts to appropriate areas.
Sanctions and PEPs
• Review / decide / escalate as appropriate PEP and sanctions referrals alerted on the BNPP Customer data base.
• Ensure relevant hits are escalated to the Due Diligence Team / FCPT – Enhanced Due Diligence (‘EDD’) Function.
• Review and assess alerts for money laundering risk, liaising with business areas as necessary, for alerts generated from BNPP transaction monitoring (‘TM’) systems (AMLS, Actimize CM, Actimize CIB).
• Review rules and settings to suggest changes, where necessary (annual basis or Ad-hoc).
• Ensure Management is made aware of all pressing issues in a timely fashion.
• 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, using the bank’s internal SAR escalation process.
• Maintain appropriate audit trail and documentation in all instances of alert review, to evidence/support the review and resolution of payments alerted.
• Manage BNPP’s US Recusal Process including the provision of appropriate training to relevant persons.
• Report any breach of legislation or bank policy via the bank’s breach reporting procedure and escalate issues to the appropriate area.
• Maintain accurate records and ensure Management Information produced is of the highest standard.
• Advisory: Review in detail any sanctions-related matter referred to the FCPT and be ready to respond on issues, risks and mitigants; whilst ensuring strict compliance with BNPP policy at all times.
Skills & Experience
• Prior financial sanctions and/or transaction monitoring experience working in an FCA regulated bank’s financial crime environment.
• Ability to apply holistic approach to identify, investigate and mitigate financial crime risk.
• Ability to consider risk mitigants as well as risk issues, when presenting a balanced opinion of those issues to line Management.
• Excellent team player within a high pressure environment.
• First class communication skills, both written and oral.
• Demonstrable 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 informed decisions on a timely basis, whilst ensuring that issues have been appropriately considered and mitigated.
• Proven experience working in an FCA regulated bank’s financial crime environment.
• Strong track record in assessing Anti Money Laundering (AML) cases and making decisions to mitigate AML risk / escalate accordingly.
• Good working knowledge of the UK AML regime and an understanding of other sanctions regimes.
• Awareness of factors influencing the content of scripts used for automated payments lists and filters (NB: No detailed technical systems capability required).
• An understanding of general money laundering and terrorist financing risk issues, relevant to product, jurisdiction and client-types.
• An understanding and awareness of other financial crime risk issues, such as, bribery and fraud.
• Proficient user of Microsoft Office (including Microsoft Excel).
Please note that all applicants must disclose whether that they possess the right to work in the U.K. as per the Immigration, Asylum, and Nationality Act of 2006.