Job Title: Assistant Vice President, Financial Crime Risk Stewardship CoE – Sanctions
Purpose of the role:
- Requires close working relationship with all stakeholders at various levels of Global, Region, Markets, Lines of Business and Functions.
- Possesses good knowledge on sanctions regulations, compliance framework, and risk & control concepts to manage and execute the FC functions in line with Global FC policy and Global Sanctions Operating Procedure.
- Highly organized and exhibit the ability to act independently and exercise discretion with minimal guidance and supervision.
- Implement Risk strategy, identifying weaknesses that pose significant impacts on businesses in meeting the strategic objectives.
- Implements and contributes to the plan established by the relevant Senior Management.
- Able to act in an organized and timely manner.
- Governance and Committee Memberships (membership of ExCos, Risk Management Meeting)
- Participate and / or represent FC at any relevant FC / Non-Financial Risk (NFR) forums hosted by FLOD or SLOD as appropriate.
In this role, you will:
- The following principal accountabilities are aligned to the Financial Crime Services and Processes Model.
- Risk management decisions on retention, exit and reporting for customers.
- Handle a portfolio of advisory cases and drive to resolution.
- Ensuring WPB and CMB Compliance and LoB teams kept informed on sanctions referrals with significant impact.
- Delegate approver for customer relationships and transactions which require approval under the HSBC Global Sanctions Policy
- Delivery of feedback to the LoB Compliance and 1st line business functions on sanctions referrals
- Production of reports to Reputational Risk and Client Selection Committees
- Delivery of feedback to Global governance committees within Sanctions, Compliance, and the LoB’s
- Advice and determination of controls designed to mitigate sanctions risk with respect to products, customer relationships and transactions.
- Performance of any responsibility delegated by the Regional / Country Head of Sanctions
- Advice and determination of sanctions matters in relation to periodic, trigger-based, or on-boarding reviews for the LoB’s in the Customer Segment section.
- Determination of potential exits and referral to the CSEM function responsible.
- Determination of internal and external breach reporting.
- Provide ‘backup’ support to the Regional / Country Head of Sanctions and the other Sanctions team members to ensure adequate coverage for any holidays or sickness.
Typical Targets and Measures
- Clear risk-based policies/advice produced and documented.
- Group FC plans in place across the FC function to agreed timescales.
- Schedule of EWRA reviews agreed and delivered to agreed timescales, with necessary change implemented.
- Review below standard audit reports, compliance reviews and reports and take the appropriate action regarding any significant compliance or reputational exceptions.
Impact on the Business / Function across the region
- Support Group communications strategy, for standards, systems, and policies in relation to Sanctions.
- Identify, assess, oversee, and communicate all requirements relating to legal guidance and sanctions evasion trends in relation to risks presented through HSBC’s business activities across (including subsidiaries).
- Support and facilitate a strategic coordination and implementation of an effective Sanctions controls framework (including subsidiaries).
- Participate the required remedial action of all material FCC sanctions issues that arise to ensure effective implementation through internal and external reviews.
- Assist in preparation of training on Sanction risks for all business products and services across (including subsidiaries).
- Implement, as required, Group sanctions policies and systems that ensure that business exposure to financial crime risk, reputational risks and emerging & arising risk is managed appropriately, in a practical, effective, and commercially focused manner including efficient and reasonable deployment of resources and an understanding of the business operations and needs.
- Provide and adapt solutions to complex global issues/initiatives in an ever changing, high-risk environment.
- Monitor the implementation of FC Sanctions controls.
- Ensure all GSM, FIMs, BIMs and dispensations, etc. are updated for changes in Country Regulation and impacts on business.
- Maintain awareness of operational risk within assigned portfolio and minimize the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.
- Support Sanctions risk Projects as SME support (Policy / Procedure, Analytics, Training etc.)
Typical Targets and Measures
- Applicable standards, policies and procedures developed, and implementation approach established.
- Ensure that standards, policies, and procedures are being designed to meet regulatory needs and plans are in place to ensure they are clearly understood by stakeholders.
- Appropriate and streamlined process is in place for identify/filtering/reporting financial crime risk.
- Clear metrics are presented to senior executives with clear analysis relevant to each LOB.
Customer / Stakeholders
- Lead / liaison with relevant stakeholder within Global / Regional Sanctions and relevant teams to provide expertise and support on all FC risk related matters.
- Ensure that appropriate, timely and relevant risk information is provided to stakeholders and Risk Management forums.
- Develop and maintain a strong and professional working relationship with relevant stakeholders within Risk & Compliance, Audit & Finance, Business Lines / Functional teams, and Global / Regional / Country level teams to provide expertise and support on all Financial Crime Sanctions related matters.
- Work effectively with Rep of Sanctions and the various Reps of FC for each business lines/ subsidiaries to ensure consistency across the FC functions.
Typical Targets and Measures
- Observations and feedback shared by the Regional Head of Sanctions and their directs.
- Required reports and MIs are submitted accurately with key highlights called out and communicated clearly and in a timely manner.
- Close working relationship maintained with the Regional Head of Sanctions and their directs.
Leadership & Teamwork: (the role-holder is expected to)
- Uphold the HSBC values (we value difference, we take responsibility, we succeed together, and we get it done)
- Drive, encourage and promote a ‘speak‑up’ culture.
- Lead by example, demonstrating core behaviors and values including teamwork, focus, drive, and determination.
- Foster a close working relationship with local Compliance and business teams, including keeping abreast of key business developments and any changes to procedures & practices, promoting proactive review of lessons learned.
- Work effectively as part of a team, taking the lead where appropriate and contributing to team output and collaboration through communication, initiative / being pro‑active, cooperation, ownership, and identification of improvements.
- Work closely with Line Manager to provide guidance and support in the management of the team.
- Leadership over all FC matters and the management of operational risk.
- Share best practice with teams in the regions and globally.
- Assist in recruitment, retention and development of colleagues and take responsibility for own development.
- Support an inclusive environment that supports diversity and reflects the HSBC brand. Ensures effective and open communication, team building, knowledge sharing, coaching and mentoring not only within the function but to the broader organisation.
Typical Targets and Measures
- Update the Regional Senior Management on the changing dynamics of FC risks regularly.
- Strategies and policies to be developed and communicated clearly and in a timely manner.
- Close working relationship maintained with the Regional Head of Sanctions and their directs.
Operational Effectiveness & Control
- Support to drive the continuing development or transformation of the Financial Crime operating model to ensure the business operates increasingly, effectively, and efficiently and can deliver HSBC's strategic goals.
- Support to establish and maintain a robust and efficient control environment across Financial Crime to ensure good operational, financial and project management and compliance with HSBC policy and procedures, together with early identification and effective resolution of issues that arise.
- Support to lead the development, implementation and maintenance of a Regional and designated Markets management information, analysis and reporting framework that supports and informs timely and effective business management and decision making at all levels.
- Support with embedding of Global FC Policy and governance frameworks across Financial Crime function to ensure quality, effective risk management and regulatory adherence.
- Proactively identify, manage, and mitigate control and process failures and, work with first line of defense to introduce remediation plans.
- Maintain awareness of operational risk within assigned portfolio and minimize the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.
- Focus on aligning the HSBC operating practices with changes in Global FC policy and regulatory risk, and ensure that the FC Risk Framework remains appropriate.
- Resolve any/all identified issues promptly, and elevate concerns to management as appropriate to ensure timely awareness of any material concerns.
- Maintain and observe all HSBC control standards and implement and observe the Global FC Policy, including the timely implementation of recommendations made by internal/external auditors and external regulators.
- Maintain awareness of operational risk within assigned portfolio and minimise the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.
- Ability to clearly identify FC risks and provide necessary analysis, advice, solutions and support.
- Ability to interpret regulatory developments and advise on its impact to business, provision of practical and compliant solutions.
Management Risk
- The management of financial crime risks is an integral part of the role profile. This role will continually reassess the operational risks inherent in FC by taking account of changing economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new technology.
- This will be achieved by ensuring all actions take account of the likelihood of financial crime risk occurring and by addressing any areas of concern in conjunction with line management and / or the appropriate department.
- Any concerns must be escalated through line management as soon as they become apparent.
Observations of Internal Controls
- The jobholder will also adhere to and be able to demonstrate adherence to internal controls. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators.
- Managers are accountable for setting the ‘tone at the top’ which underpins the principles of a positive and effective internal control environment. They should exhibit leadership and direction to their teams for establishing and maintaining an effective internal control environment, including the development and management of policies and procedures where appropriate. Managers should also ensure that suitable processes are put in place to review and oversee the internal control environment against those policies.
- The nature of the role requires close working contact with Global, Region, Markets, Senior Executives in FC, Lines of Business and Products and other functional areas such as DBS /IT / Legal etc.
Major Challenges
- HSBC is an extremely diverse business with significant geographical spread and activities that span a universal banking model, including continuing to innovate to keep abreast of changes in financial services markets globally. Such activity is in an increasingly regulated and complex global environment with often little consistency between laws and regulations in different jurisdictions and regulators taking a far more proactive approach in ensuring local compliance with their requirements and imposing increasingly stringent sanctions for breaches.
- The incumbent is required to ensure the consistent application of the highest risk management standards, notwithstanding the complexities of business operations across regions. The incumbent would identify, plan, and implement change programs to ensure that HSBC remains in line with regulatory requirements across the Group.
- This role also needs to operate within a matrix environment, requiring strong leadership skills to collaborate with multiple stakeholders and deliver results. The role holder must be able to influence senior management and articulate clear business reasons for change initiatives, within the scope of this role.
- To drive change in culture with respect to the management of FC Risk, in accordance with the three lines of Defence model. To manage the inter‑linked and competing demands of developing, implementing, and improving strategic Financial Crime systems and controls on a Group wide basis, while also providing for adequate commercial view and balance.
Role Dimensions
- The job holder will be an individual contributor reporting to VP FC CoE Risk Stewardship.
- This can involve dealing with major issues for which there is no clear‑cut solution whilst still be able to provide judgment and clear direction. Where items of major consequence are involved, engagement with the relevant top‑level management will be expected, directly and through collaboration with Vice President Risk Stewardship – Sanctions and Head of FC Risk Stewardship COE, as appropriate.
To be successful you will:
- The candidate must have an overall work experience of 8‑10 years in the banking / financial services industry.
- At least 5‑6 years of working knowledge of Sanctions, i.e. understanding of UK/EU/UN/US sanctions regimes and regulations, Export control breaches, Screening and Payment transparency etc.
- Understanding of Risk frameworks under Financial crime.
- Good understanding of the Sanctions Risks and Controls framework e.g. FCA rules on Systems and Controls, OFAC’s Framework for Sanctions Compliance Programs etc.
- Interpersonal Skills (i.e., collaboration and networking) with experience of dealing with stakeholders including the capacity to articulate the case for risk management.
- Excellent communication skill (oral, written, and presentational) with the ability to influence others through use of compelling facts, thought‑provoking discussion and logic and use diplomacy and tact to resolve differing views.
- Ability to lead change, contributing to joining up with the other teams in Risk and Compliance and Business globally.
- Ability to work independently on distinct tasks, escalating as appropriate and able to "connect the dots" and critically analyse situations, recommend effective solutions to problems, and identify or anticipate regulatory concerns.
- Strong critical thinking and analytical skills. Ability to make informed risk‑based decisions with robust supporting rationale.
- Effective Time management & prioritisation skills with an ability to prioritize competing demands and deliver against stringent deadlines.
- Knowledge in MS Office Suite, MS PowerPoint & Excel is mandatory.
- ACAMS or International Compliance Association (ICA) certificate/diploma, or equivalent qualifications (Preferred)
www.hsbc.com/careers
You’ll achieve more at HSBC
HSBC is an equal opportunity employer committed to building a culture where all employees are valued, respected and opinions count. We take pride in providing a workplace that fosters continuous professional development, flexible working and, opportunities to grow within an inclusive and diverse environment. We encourage applications from all suitably qualified persons irrespective of, but not limited to, their gender or genetic information, sexual orientation, ethnicity, religion, social status, medical care leave requirements, political affiliation, people with disabilities, color, national origin, veteran status, etc., We consider all applications based on merit and suitability to the role.
Personal data held by the Bank relating to employment applications will be used in accordance with our Privacy Statement, which is available on our website.
***Issued By HSBC Electronic Data Processing (India) Private LTD***