The bank for a changing world

Vice President – CUSO/IHC Financial Security Risk Assessment

Contract

Standard / Permanent

Location

US-NY-New York

Job function

COMPLIANCE

Reference

COM000841

Business Overview:
 
As part of the Enhanced Prudential Standards (EPS), the Federal Reserve requires banking organizations to establish an Intermediate Holding Company (IHC), in attempt to regulate them in parity with comparably-sized domestic Bank Holding Company (BHC) and to establish a risk management framework, including compliance risk, over their combined U.S. operations (CUSO). The BNP Paribas CUSO/IHC Program is structured at the U.S. level across poles of activities of BNP Paribas and provides guidance, supports the analysis, conducts impact assessment and drives adjustments of the U.S. platform’s operating model.
 
The IHC framework is currently under development, with a regulatory implementation date of July 1, 2016
 
The primary responsibility of the VP – CUSO/IHC Financial Security Risk Assessment is to assist the CUSO/IHC Compliance function with financial security risk assessment matters across the CUSO/IHC and the Operating Entities/Business Divisions, namely CIB, IP, BoW, and FHB.
 
Responsibilities:
 
This position covers the development, implementation, and maintenance of risk assessment methodologies covering Bank Secrecy Act (“BSA”)/anti-money laundering (“AML”) and sanctions obligations as well as the preparation of consolidated financial security risk assessment reporting across the CUSO/IHC and the Operating Entities/Business Divisions. Key responsibilities of this position include:
  • Supporting the development, implementation, and maintenance of a CUSO/IHC BSA/AML Risk Assessment Methodology and a CUSO/IHC Sanctions Risk Assessment Methodology;
  • Developing and implementing an approach to aggregate BSA/AML and sanctions risk assessment results across the Operating Entities/Business Divisions to provide senior management and the board of directors with a consolidated view of financial security risks across the CUSO/IHC;
  • Coordinating the launch of annual BSA/AML and sanctions risk assessments across the Operating Entities/Business Divisions and overseeing the administration of Operating Entity/Business Division BSA/AML and sanctions risk assessments;
  • Conducting sensitivity analyses of the CUSO/IHC BSA/AML and Sanctions Risk Assessment Methodologies to test the robustness of the approaches used to aggregate financial security risk assessment results;
  • Preparing annually consolidated CUSO/IHC financial security risk assessment reports for presentation to senior management and the board of directors;
  • Working with other CUSO/IHC compliance stakeholders to use the results of the financial security risk assessments to inform other compliance program activities, such as financial security testing and training;
  • Assisting the Operating Entities/Business Divisions with developing and maintaining an inventory of key controls to mitigate BSA/AML and sanctions risks;
  • Monitoring the implementation of corrective action plans to mitigate the risks identified in the course of the BSA/AML and sanctions risk assessments;
  • Coordinating with Group Financial Security in Paris and New York on financial security risk assessment matters and assisting the Operating Entities/Business Divisions with participating in Group-wide risk assessment campaigns; and
  • Assisting the CUSO/IHC Compliance function with other risk assessment matters, as appropriate.

  • Bachelor’s degree or equivalent required
  • Minimum of 8 years’ experience in banking or other financial institution setting, with a focus on enterprise risk management or compliance risk management
  • Strong knowledge of legal and regulatory requirements in the financial security space (e.g., Bank Secrecy Act, Foreign Assets Control Regulations, Export Administration Regulations, etc.)
  • Broad knowledge of financial products and services across the retail and non-retail sectors
  • Strong writing and comprehension skills
  • Experience in risk identification, assessment, and aggregation processes
  • Familiarity with corrective action and other control remediation processes
  • Strong project management skills with the ability to multi-task and manage competing priorities
  • Team player and ability to work collaboratively
  • Ability to establish and maintain strong relationships
  • Flexibility and adaptability
  • Proficiency with Microsoft Office products (Word, Excel, PowerPoint)

"BNPPRSR"