- Bank is committed to the highest standards of Anti-Money Laundering (AML), Sanctions & Embargoes, Anti-Bribery and Corruption (ABC) and Anti-Fraud & Investigations (AF&I) and wider Financial Crime (collectively referred to as Anti Financial Crime) prevention. The Management and all employees are required to adhere to these standards to prevent Bank and our reputation from those who may intend to use our products and services for money laundering, bribery, corruption, fraud and/or Terrorist Financing (TF) purposes.
- Bank will examine its Anti-Financial Crime (AFC) strategies, goals and objectives on an ongoing basis and maintain an effective program for Bank’s business that reflects the best practices for a diversified, global financial services provider.
- The AFCO function is responsible for the AML, CTF, Sanctions & Embargoes, Anti-Fraud & Investigations (AFI), ABC activities in the jurisdiction where relevant.
- The purpose of AFCO’s role is to assist the Country AFCO in completing with AFC related roles and responsibilities.
Position Specific Responsibilities and Accountabilities
- Assist Country AFC Officer (AFCO) in advising on and ensuring implementation of AFC policies and procedures whereas involvement in ABC and AFI policies depends on the availability of headcount in the location and if none, this will be assisted by the respective regional team.
- Assist Country AFCO in advising on the impact of new AFC related internal and external rules and ensuring that local guidelines and procedures are in line and reflect German and local laws / regulations. Escalate exceptions to the Regional Head of AFC.
- Assist Country AFCO in assessing the conformity of internal policies and procedures, systems and controls with relevant regulatory obligations and Bank standards.
- Being third point of contact for AFC matters with competent regulatory, law enforcement or other public authorities in their jurisdiction, and in the absence of local ABC and AFI headcount, in conjunction with the respective regional heads subject to the assignment of Country AFCO
- Assist Country AFCO in reporting and liaising with Regional Head of AFC and other AFC Senior Management to ensure appropriate reporting and escalation of issues and/or incidents.
- Assist Country AFCO in contributing to Bank AFC Function as a whole by sharing knowledge and best practices with AFC Officers of the other Businesses and entities and other AFCOs. -Contribute to the development of AFC methodologies by cooperating with other disciplines like Compliance, Legal, Audit and Operational Risk Management.
- Assist Country AFCO in ensuring timely delivery of the local AFC Risk Assessment in the country leveraging off regional assessments performed for ABC and AFI topics.
- Assist AFCO in providing AFC advice in the change management process including but not limi to the New Product Approval (NPA) and Vendor Risk Management (VRM) Process.
- Assist Country AFCO in helping maintain an AFC compliance staff awareness culture by providing appropriate training to staff and arranging training by other regional leads for Sanctions & Embargoes, ABC and AFI.
- Oversight of local Training and ensure that AFC Training requirements are met in conjunction with the aforementioned leads.
- Assist Country AFCO in developing and maintaining the AFC related Internal Control Framework under advice from Regional AFC Risks & Controls to ensure adequate monitoring and control measures are implemented, report on any findings and advise management on remedial actions to take.
- Complying with the requirements set by the AFC Global Controls Programme. Assist AFCO in develop and carry out adequate controls to ensure that all applicable legal and regulatory AFC requirements are being adhered to in their jurisdiction
- AML:Assist Coutntry AFCO in maintaining especially an adequate Internal Control Framework for Unusual and/or Suspicious Transactions in terms of organization, administration systems and controls to ensure properly and timely detection, investigation and reporting of unusual and/or suspicious transactions or activities to competent authorities in compliance with applicable rules.
Assist Coutntry AFCO in implementing adequate monitoring – research /surveillance tools.
- Assist Coutntry AFCO in discharging the responsibilities of AFC as set out under global KYC policies for divisions present in the jurisdiction.
- Assist Coutntry AFCO in making decisions on new or existing clients that are escalated, or decide to escalate further.
- Assist Coutntry AFCO in tracking and following-up on the conditions that have been imposed as part of the KYC approval.
- Assist Coutntry AFCO in following-up with the Business on status of Regular Reviews and obtain relevant MIS from the Business.
- Sanctions:Assist Coutntry AFCO in monitoring local regulatory sanctions developments and notifying relevant changes and specifications to the Regional Head of Sanctions.
- Discharging the responsibilities of the Group Embargo Office locally as set out in the Group Embargo Policy and in the Special Risk Country Policy, in particular, ensuring implementation of applicable sanctions requirements on a country level.
- Anti-Fraud:Assist Coutntry AFCO in assuming and promoting AFC’s responsibility for anti-fraud in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional AFI teams.
- In Vietnam where the AFCO has no dedicated AF&I headcount, the Local AFC Officer will assist the AFCO in making reports to the relevant Regional Head of AF&I all fraud matters for central tracking and reporting.
- The regional AF&I team will assess if further regional support is required in delivery of local anti-fraud responsibilities. .
- Anti-Bribery & Corruption:Assist Coutntry AFCO in assuming and promoting AFC’s responsibility for anti bribery & corruption in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional ABC teams.
- In Vietnam where the AFCO has no dedicated ABC headcount, the Local AFC Officer will assist the AFCO in making reports to the relevant Regional Head of ABC all bribery and corruption matters for central tracking and reporting. The regional ABC team will assess if further regional support is required in delivery of local anti-bribery & corruption responsibilities. The regional ABC team will retain the lead in reviewing risks associated with certain ABC functions, specifically review of connected hire candidates and Business
- Development Consultants risk assessment per Policy, they will involve the local AFCO as it impacts their location.
- Assist Coutntry AFCO in ensuring that AFC Employee Reliability Requirements are met.
- Assist Coutntry AFCO in ensuring that local record keeping processes are in alignment with the AFC related legislative, regulatory and internal requirements.
- Assist Coutntry AFCO in providing input for MI reports requested by Global AFC or the AFC reporting function.
- Implementing any Governance related controls, processes and procedures as directed by the AFC Governance function.
- Assist Coutntry AFCO in ensuring the local implementation of any country, regional or global AFC projects and programs in conjunction with the relevant regional leads. Assist AFCO in ensuring the local implementation of any country, regional or global AFC projects and programs in conjunction with the relevant regional leads.
- 5-7 years of experiences in banking and/or financial industry of which at least 3 years either on Anti Financial Crimes, Anti Money Laundering, Know Your Client or Compliance, Risks or other Control Functions are preferred;
- Strong understanding of banking products, process, anti financial crimes risk and controls;
- Strong knowledge or experience in IT / database is a plus;
- Analytical thinking, risk and control oriented;
- Confident and articulate partner to multiple functions;
- English fluent.
- Bachelor Degree, preferred in Law, Banking or Economy
If you are open for a new opportunity, please contact Mr. Anh Tran at firstname.lastname@example.org for a confidential discussion.