Job Title: VP Financial Crime Infrastructure
Financial Crime Risk Stewardship
- The Financial Crime (FC) team operates as a Second Line of Defence (2LOD) Infrastructure. It includes Risk Stewards, who remain independent of the commercial risk-taking activities undertaken by the Group’s businesses, referred to as the First Line of Defence (1LOD or FLOD).
- In addition to its stewardship responsibilities, the FC Infrastructure operates a set of critical controls on behalf of the FLOD, using intelligence, analytics, technology, detection and investigation capabilities. Risk Stewards review and challenge the activities of the FLOD to ensure that, as Risk Owners, businesses effectively and efficiently manage the financial crime risks inherent in, or arising from, their activities.
- Financial crime risk is a non-financial risk covering areas including: Fraud, Money laundering, Bribery and corruption, Sanctions violations, Terrorist financing, Proliferation financing, Export control violations, Tax evasion.
- The FC Infrastructure operates in compliance to the Global Financial Crime Policy (GFCP).
- The Vice President, Financial Crime Infrastructure resource will support the Head of Financial Crime, IWPB and Infrastructure, including Global Infrastucture effectively and efficiently identify, assess and manage the financial crime risks to which they are exposed. The current Infrastructure FC CoE operating model has met existing demand for Group Infrastructure and GCN/HT. However, the FC Risk Stewardship future-state remit will expand materially to provide Markets coverage across multiple locations (ASP, US, LAM, HCIB, UK, HK and MENAT) and will assume a more direct, front-facing stewardship leadership role for Infrastructure activities currently delivered by Global SME teams.
Governance representation:
- represent Global Infrastructure in governance forums, providing clear updates on progress (both verbal and written), key issues, decisions required, and provide advice as needed.
- Proactive risk management: Maintain a forward-looking view of regulatory change, industry best practice and evolving Financial Crime typologies, consider their impacts to HSBC, and work with stakeholders to consider and appropriately shape downstream impacts.
In this role, you will:
The key responsibilities include but not limited to:
- Team management: work across the Global Infrastructure to lead, support and coordinate priority activities required to maintain and improve the effectiveness of the financial crime risk management framework. And someone who understands the existing Infrastructure structure and framework.
- Subject matter expertise: Provide expert guidance and constructive challenge across a broad range of Infrastructure matters, including policy development, control design and effectiveness, escalations, issues and actions, risk management, and management information. The role will work closely with the FC CoE network and a broad range of stakeholders to support effective governance and delivery.
- The position requires strong technical expertise and proven experience in Anti-Bribery and Corruption (AB&C), Fraud Risk, particularly staff and internal fraud, and third-party risk management, including Associated Person considerations. It is expected to this role to have solid understanding on employee and non-employee vetting related activities where Financial Crime risks are involved , screening, non-customer Sanctions exposures and Tax Transparency controls. It also requires confident senior stakeholder management skills to secure outcomes across Global Infrastructure and relevant governance forums.
- A key responsibility will be third-party stewardship. The role will lead this agenda, represent Infrastructure credibly in senior forums, and establish a clear oversight framework covering the appropriate scope and coverage model, evidence and assurance standards, escalation and decision-making triggers, and effective remediation tracking.
- The role holder will be expected to drive timely and sustainable remediation, ensuring that identified risks and issues are addressed at pace and brought to effective closure.
- Risk Assessment Stewardship: It is important for this role to have strong understanding and have experience of the RCA Scoping review and challenge. Supervise the review of Infrastructure RCAs, control descriptions, residual risk descriptions, trigger events, incident management follow up and perform first level review on the quality of the inputs, & completeness.
- Cross-functional collaboration: proactively identify, assess and prioritise emerging threats, risks and control weaknesses, translate these into clear impacts for stakeholders, and drive timely updates across the risk management framework. Where required, act as a point of escalation across the FC CoE on behalf of Global Infrastructure.
- Insights and executive reporting: analyse and critically assess insights from multiple sources to shape Global Infrastructure executive-level reporting, for example, inputs to Senior Manager Regime, Risk Maps and on Metrics. Responsibility includes representation of the Head of FC, WPB and Infrastructures to any Global Infrastructure governance forums and provide challenge and guide the Infrastructures teams where risks are not managed effectively
- Strategic enhancements and simplification: support strategic enhancements and simplification efforts to improve processes, controls, risks management activities, MI etc, aligned to Global Infrastructure activities. This may also include applying a practical understanding of automation and/or AI-tooling to support optimisation.
Principal Accountabilities: key activities and decision-making areas
The following principal accountabilities are aligned to the Financial Crime Services and Processes Model.
Impact on the Business
- Proactive approach to the identification of FC risk change and potential impacts.
- Work closely with relevant stakeholders within Infrastructures to provide expertise and support on all financial crime related matters
- As one of the managers within the FC organization, the incumbent should drive consistency in messaging throughout the organization and building a culture of transparency between FC and 1LOD.
- Respond swiftly and clearly to Group/ Senior Executive / Global Business’s evolving requests and requirements.
Customer / Stakeholders
- Lead / liaison with relevant stakeholder within markets 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 and Compliance, Audit and Finance at Business, Group and Regional levels
Leadership and Teamwork
- Management responsibility for a team of professionals, including people, performance, budget and planning decisions
- Drive attainment of Infrastructureal/Infrastructureal unit results
- Share best practice with teams in the regions and globally.
- Maintain and develop positive and professional working relationships with senior business managers across markets. Lead by example, demonstrating excellent behaviours in line with HSBC core values.
- Assist in recruitment, retention and development of colleagues and take responsibility for own development.
- Work effectively as part of a team, taking the lead where appropriate and contributing to team output and collaboration.
- Foster a learning agile culture, promoting proactive review of lessons learned.
- 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 Infrastructure but to the broader organisation.
Operational Effectiveness and Control
- Focus on aligning the HSBC operating practices with changes in Global FC Policy Standards 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 GFCP, 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.
- Leadership over all FC compliance matters and the management of operational risk.
- 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.
- Ability to deal with Senior Management and Business in a professional and proactive manner.
Management of 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 the Markets 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.
Observation of Internal Controls
- 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.
Local Job Requirements
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 Financial Crime 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 Context
- The role will support the support the Group Head of FC, WPB and Infrastructures and report to the Head of FC Infrastructure within FC COE.
- This can involve dealing with major issues for which there is no clear-cut solution whilst still being 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 Group Head of FC, WPB and Infrastructures , Infrastructureal stakeholders and Head of FC Infrastructure - COE as appropriate. The nature of the role requires close working contact with senior executives across the Group.
To be successful you will:
Certifications, Qualifications and Experience
- Significant experience in Financial Crime Risk management advisory or similar Risk Infrastructure.
- Proficient knowledge across all Financial Crime risks in the financial services industry
- Working experience within the Infrastructure teams is desirable
- Strong understanding of how controls mitigates FC Risk and the various underpinning activities forming the overall Risk Management framework.
- Excellent communication and inter-personal skills, with experience of dealing with executives at all levels including the capacity to articulate the case for risk management.
- Experience of interpreting and analysing a large volume of information and / or data and provide succinct summary for management.
- Experience of working within a matrixed environment preferred including reporting internationally.
- 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.
- Experience in leading a team / group of individuals
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