Informed compliance confirmation and reportingSupport BCO to provide informed and evidenced compliance confirmation in order for BCO to provide advisory support to Board/MD on planning, implementing and overseeing compliance risk related issues on all Business Pillars within SBG/SFG level. Attend the meeting with senior managements for discussion and clarification on significant compliance matters as well as acting as GWB representative to attend the meeting with relevant stakeholders for discussion and clarification on relevant regulations and policy; Formulate the diversified compliance procedures, guidance, and strategic direction for GWB business. Acting as the GWB's representative for Group Audit checks, Compliance Testing, and Regulator Checks. Perform health check to assess the compliance level of business/function and timely escalation. Develop the required tool for the assessment including the controls to mitigate compliance risk. To ensure there is no error/incident based on the health check as evidence for quality assurance. Prepare consolidated divisional reporting for BCO's review on regulatory and AML/CFT reporting. e.g. Prepare report based on what need to be presented to the various committee meetings including to GMC/Board – e.g. report on high risk client. Escalate divisional compliance risk appetite breaches to BCO.
e.g. BRCS to be able to identify compliance risk as a control owner within 1st line in order to proceed with escalations to BCO and 2nd line.
Ensure control and actions to mitigate compliance risk is being implemented for area of coverage. e.g. Incidents / high risk items to be followed up for closure / mitigation.
Assist BCO to prepare and documenting detailed procedure for better oversight/governance of BCO. e.g., Procedure to be up-to-date and covers all area of regulatory requirements and to be able to challenge front line procedures.
Regulatory and AML/CFT self-assessment- BRCS to perform sanity check/validation on the completed Compliance Risk Assessment (CRA) / Anti Money Laundering Risk Assessment (AMLRA) by the BA/FA heads.
- Actions taken to ensure risks are mitigated and CRA/AMLRA rating are within acceptable rating and to submit on time.
- To review and guide business to complete the Product Risk Assessment by collaborating with both process and product owner.
- BCC to ensure that the Self-Assessment Advertisement Checklist and Self-Assessment Term & Conditions Checklist are completed and reviewed by the BCO, RRCO and Group Marketing prior to the issuance of such material.
Strategic Operational Risk ManagementAssist BRO by providing informed input and assessment on Non-Financial Risks related issues (Operational, Fraud Corruption, Business Continuity & Operational Resiliency and Technology & Cyber Risks) for their respective BG/FG/SBG/SFG/SBS/SFS. This enables BRO to provide advisory support MD SFS Head and ensuring that all non-financial risks related issues are considered and accounted for as part of the strategic plans. Analyse relevant Group Bank risk appetites related to NFR, assist and provide inputs for BRO to recommend appropriate supporting metrics within SBG/SFG/SBS/SFS level. Act as the first contact point for BG/FG/ SBG/SFG/SBS/SFS to identify and incorporate NFR concerns into product and business proposals, including advising on process designs governance consideration so that the proposals conform with the defined standards from the early stages.
Advisory and Monitoring on core risk management tools & functions - RCSA/KCT/KRI/LDC/BCM/PRCA/Shariah Risk etcFacilitate annual review and ad-hoc review of ORM Tools i.e. RCSA (including RTP), KCT and KRI, and work with the subject matter experts within the business/ functional units throughout the ORM Tools Annual Review and CORR exercise. Review and ensure the KCT results (include action plans) is complete, accurate and timely submitted to GORM. Ensure all KCT/KRI exceptions have been logged in OpRisk Evo System on a timely manner and all information logged are complete and accurate. Assist the process owner to identify the need to perform PRCA, assess residual risk rating, completing PRCA documentation and ensure post-approval matter, if any, is being carried out. Review and ensure Shariah non-compliance risk considerations integrate within the GWB operational risk management i.e. RCSA. Monitor and follow up on progress until completion/sign-off of BIA exercise within timeline. Lead the Business Continuity Plan (BCP) Test, Call Tree Test Exercise, BCM Manual review and outsourcing review is completed in timeline manner.
1st LOD Advisory on Risk & Compliance Matters1st point of contact on risk, regulatory and AML/CFT related queries. eg: BRCS to be able to advise on standard/common queries. Complicated queries to be escalated to BCO or BRO to assess the queries first and get feedback and further guidance from IB Compliance or GNFR. Provide guidance to internal clients on appropriate interpretation and application of internal and regulatory policies/procedures. Provide training on updated regulations and/or policies and procedures to the business. Handle complex queries from business units such as IB business units. To communicate/brief the staffs on new risk/regulations/guidelines. e.g. Front-liners unaware of procedure changes or new guidelines, hence to brief on all relevant guidelines. e.g. List of the briefing conducted to be maintained as an evidence. e.g. Accountable to provide confirmation that the regulatory/risk requirement and policy/procedure effectively implemented at business. e.g. Accountable for the effectiveness of the AML controls at business. Advise business to complete surveys/exposure drafts as per request from IB Compliance or GNFR. Obtain approval from BCO or BRO. To perform gap analysis on new or revised regulatory requirements and develop/drive implementation of action plan to address any gaps noted. Seek guidance from subject matter experts at IB Compliance or GNFR on regulatory matters. Responsible to review and provide feedback from compliance risk perspectives for any papers, issues or recommendations escalated management/committee for deliberation/decision.
People Development- Perform compliance & risk training needs analysis for respective business units under BRCSs purview and identify training needs. e.g. Identify role specific training/soft skill.
- Customize training material by working closely with BCO & BRO and subject matter expert with IB Compliance /GNFR.
- Coordinate execution of training (various training method).
Record keepingBRCS to ensure the record keeping of 7 years or more (as required) is in place for the department. Assurance to be given to BCO & BRO periodically. eg: BRCS to evidence this by conducting periodic sample checks on the availability of the documents. This to be included in health check. Example of documents to be reviewed - customer account opening form after the customer closed account 3 years back. To check if the forms are available for 7 years.