Financial Crime Prevention Manager in London

Principal Purpose of the Job

To support the Bank’s MLRO in maintaining an effective and efficient financial crime prevention framework. Maintaining an effective sanctions compliance framework in line with the UK, US, EU and UN regulatory expectations.

• FCP Assurance and Advisory related tasks, which includes: High Risk Case reviews; EDD Reports; FCP Escalations for guidance and approval; risk amendments requests on system; Exceptions and Waivers review; Client off boarding; PEP Risk assessments; and update and manage relevant logs (e.g. Sanctions, PEPs, Exceptions/Waivers).
• Draft, review and update FCP related policies, procedures and manuals.
• Undertake comprehensive risk assessments which are part of the FCP monitoring plan.
• Undertake QA reviews which are part of the FCP monitoring plan.
• Actively manage the FCP advisory inbox, along with relevant Trackers and logs.
• Assist the line manager and the peers in the team as and when required.

Report directly to the MLRO of the Bank, supporting in the oversight and management of the Bank’s efforts in preventing and detecting financial crime risks.

• Provide financial crime prevention (FCP) advisory across the Bank with an emphasis on Sanctions, ABC, TF, Fraud prevention and CDD in accordance with relevant laws, regulations and internal policies.
• Undertake thorough assessment of CDD files (especially High risk and EDD reports), and subsequently provide comments, rationale and obtain MLROs approval.
• Undertake thorough assessment of financial crime risks as part of the customer due diligence process.
• Proactively support the team with comprehensive risk assessments including EWRA, Country Risk, Product Risk, Client Risk, Third Party Risk, Bribery & Corruption Risk, Fraud Risk.
• Review Gifts and Hospitality requests, and provide adequate assessment.
• Manage daily responsibilities of the Financial Crime advisory function, provide support, guidance and training to the relevant staff across the bank, and maintain an effective management reporting line.
• Maintain an awareness of current Financial Crime regulations and legislation and ensure that changes are reflected in the following Bank’s policies, procedures and appendices: Anti-Money Laundering (AML), Customer Due Diligence (CDD), PEP, Sanctions, Fraud, off boarding, Anti-Bribery & Corruption, Trade Finance, Gifts & Hospitality, Sanctions, Country Risk Assessment, and Customer Risk Rating Methodology.
• Undertake systems functionality and framework testing for CDD, Trade Finance, Fraud, Sanctions.
• Perform ongoing reviews as determined by the FCP monitoring plan.
• Ensure completion of quarterly CDD and Trade Finance QA reviews.
• Where applicable, undertake annual reviews and assessments which are part of the FCP monitoring plan.
• Support delivery of the Bank-wide Financial Crime Risk Assessments.
• Ensure ‘group-wide’ policies and procedures are implemented as and where applicable.
• Assist Head Office with Sanctions Risk Assessments and other Sanctions related matters.
• Support the Transaction Monitoring team with the clearing of STORMS alerts in case of high volumes or absences.
• Attend KYC due diligence calls/meetings with counterparties and generate call reports.
• Re-open, suspend and reactivate clients on relevant systems.
• Maintain personal and professional development and training in order to discharge responsibilities.
• Design FCP related course materials and ensure staff within the Bank receive adequate training in: AML, CTF, Sanctions compliance, Fraud identification and detection, ABC, new starter’s financial crime induction (monthly) and other financial crime related matters.
• Review and approve Trade Finance escalations.
• Support and assist the MLRO with relevant reports, such as MLRO, MIP, EWRA, HO, FCA and other relevant reports.
• Ensure any other FCP related tasks assigned by the direct line manager are completed in a timely manner.

Skills and Experience Required:

• Strong technical financial crime and regulatory and legislative knowledge, including Money Laundering, Terrorist Financing, Sanctions, Fraud, Bribery & Corruption, Trade Finance, Facilitation of Tax Evasion and Modern Slavery.
• Strong Trade Finance, Sanctions, Fraud prevention and ABC advisory experience, preferably gained from acting as a SME in a bank/financial institution.
• Strong Knowledge and previous experience in Trade Based Money Laundering is a must.
• Practical knowledge and experience of the following: JMLSG, MLR 2017, POCA 2002, EUMLD, The Bribery Act 2010, International Sanctions.
• Exceptional attention to detail and good application of the risk-based approach.
• Experience of sanctions payment screening and transaction monitoring systems.
• Experience in financial crime compliance or audit roles with demonstrable career development.
• Track record of performing in a wholesale banking environment with exposure to high risk scenarios.
• Good knowledge of the relevant FCA rules pertaining to sanctions and financial crime systems and controls and UK Money Laundering Regulations.
• Strong second line advisory experience within the areas of financial crime compliance specifically in Trade Finance, Sanctions and Fraud prevention and detection.
• Ability to undertake research and analysis and exercise sound judgement.
• Ability to balance risk and practicality to determine appropriate action and solutions.
• A proactive and effective problem solver with good communication skills.
• Excellent stakeholder management experience with a focus on interaction with the Business and an ability to balance risk management considerations and commercial factors.
• Ability to be proactive and think outside of the box in terms of introducing and enhancing control process, reporting, and FCP oversight.
• Proven team player who can fit comfortably into new environments, work diligently at all levels with meticulous preparation, attention to detail and commitment, and a track record of delivering results.
• Previous payment, banking, law enforcement, or regulatory experience.
• Proven experience in entity types such as, Funds, SPVs, Trusts, Foundations, Charities and LLPs.
• An understanding of complex ownership structures and experience of the breadth of Financial Crime requirements for a range of corporate and FI entities both in the UK and overseas is essential.

Other Factors:

• Bachelor's Degree or higher education (preferred).
• Diploma or higher education in Financial Crime Prevention from ICA, ACAMs or equivalent is a must.
• Certification and/or a diploma in Sanctions compliance is a must.
• The job holder may be asked from time-to-time to provide assistance on wider compliance issues.