To establish and maintain an effective and sustainable Financial Crimes Compliance (FCC) Program/ Framework (Policies, Procedures, Systems & Controls, Technology, and other Resources) to ensure adhere to all applicable laws, rules & regulations and industry best practices for preventing, detecting and mitigating illegal activities like money laundering, financing of terrorism, proliferation financing and sanction evasions.
Key Job Responsibilities
- Overall supervision and oversight of FCC Unit for managing all functional responsibilities and administrative matters to exercise an effective FCC Program across the Bank to manage the risk of money laundering (ML), financing of terrorism (TF) and proliferation financing (PF).
- Establish AML/CFT/CPF Policy, Sanction Screening Policy and other related policies and procedures and keep them updated in line with internal and external changes.
- Develop and implement a Bank-wide risk-based FCC Program/Framework aligning with the local and international laws and regulations and best practices for effectively managing the risk of financial crimes.
- Lead FCC function and oversee the Bank-wide implementation of FCC controls as required by the FCC Program.
- Ensure FCC function has all necessary IT Systems, tools and techniques including Sanction Screening and Transaction Monitoring Systems and resources to exercise an effective FCC Program across the Bank.
- Responsible for continuous and sustainable improvements and innovations in IT systems, procedures & processes, controls and practices, so the systems are capable to the protect the Bank against ML, TF and PF risks and any other emerging risks related to FC.
- Responsible for exercising effective oversight of list management processes to keep all the lists updated in timely manner.
- Ensure escalation of potential FC risks/ events to appropriate management level for their timely mitigation/ remediation.
- Provide timely advice/ guidance on all FC related matters across the Bank for taking corrective measures/ actions by relevant function(s) to manage the risk of financial crimes.
- Provide advisory services to Operations & Business functions on problems/ issues faced by them to comply with financial crimes related regulatory requirements.
- Responsible for investigation of potential FC risks/ events and presenting the findings to CCO, for further escalation to senior management and management committees.
- Establish CFT Desk and monitor its activities to comply with regulatory requirements.
- Responsible for timely submission of CTRs and SARs and STRs to Financial Monitoring Unit (FMU) as per regulatory guidelines.
- Review and approval of accounts of Politically Exposed Persons (PEPs) and high-risk customers as per regulatory requirements and internal policy.
- Responsible for implementation of findings/ recommendations highlighted in Internal Audit Reports or SBP Inspection Reports to further strengthen systems and controls to improve efficacy and effectiveness of FCC Unit.
- Responsible for the implementation of recommendations received from Senior Management, CCM or BRMC to improve the functioning of FCC Unit.
- Liaison with SBP and other regulators and Law Enforcement Agencies (LEAs) to facilitate them in timely provision of information, as and when required by them.
- Assist the CCO in managing Compliance Committee of Management (CCM), Board Risk Management Committee (BRMC) or any other committee or forum.
- Represent CCO in internal meetings or Compliance Forums organized by SBP or any other regulator or authority, if needed.
- Responsible for staff training and development to enhance their knowledge and skills for improved and better performance.
Qualification, Certification, Knowledge & Skills and Experience
Bachelor’s degree from an HEC recognized Institute/University. Master’s degree shall be given preference.
Certification
Certified Antimony Laundering Specialist (CAMS) or any other internationally recognized certification. Candidate having relevant certification(s) shall be given preference.
Job Specific Skills
The incumbent must have thorough knowledge and understanding of:
- Banking Business and Operations.
- Anti-money Laundering Act-2010, Anti-terrorism Act-1997 and other related acts & laws.
- SBP Anti-money Laundering (AML), Combating the Financing of Terrorism (CFT) and Countering Proliferation Financing (CPF) Regulations.
- SBP Guidelines on Targeted Financial Sanctions (TFS) under UNSC Resolutions-AML/CFT/CPF Regulations.
- Recommendations of Financial Action Task Force (FATF).
- UNO Sanctions – Countries & Sectoral Sanctions.
- Other laws, rules and regulations applicable to financial crimes.
Behavioral Skills
- Leadership & Team Management
- Good Communication and Interpersonal Skills
- Commitment to Excellence
- Agile and Result Oriented
Experience
- 10 to 15 years’ working experience in managing FC Compliance, including 5 years at senior level i.e. AVP to VP or Unit Head. Must have experience in areas like AML/CFT, KYC/CDD, Transaction Monitoring & Sanction Screening, managing CFT Desk, evaluation of PEPs & high-risk accounts, ultimate beneficial owners (UBOs), goAML, etc.