Job Description The Head of Controls manages the core operational processes executed in FCC, as well as the specialist supporting systems for surveillance/screening; to help promote and manage throughout Nigeria the culture and practice of FCC risk management within the letter and spirit of relevant laws and regulations.Key Roles and Responsibilities Provide oversight and management of country roles including Head, Surveillance and Analytics Responsibilities * System and tuning oversight for surveillance, screening and Customer Due Diligence (“CDD”) * Apply quantitative techniques to develop intelligence and tune systems to better identify and mitigate risk efficiently * Build solutions to monitor for financial crime typologies * Maintain documentation for systems owned in FCC, e.g. rule book Head, Financial Crime Investigations Responsibilities * Manage alert/cases/SARs * Manage escalations from the business * Manage escalations based on customer screening alerts * Manage production orders escalated to Financial Crime Compliance (“FCC”) Head, Financial Crime Intelligence Unit Responsibilities * Oversee media/other research and monitoring * Maintain country watch lists * Manage law enforcement outreach and outreach to banks on intelligence * Support complex Group or cross-jurisdiction investigations Head, Quality Assurance and Performance Responsibilities * Undertake quality assurance in relation to all core Financial Crime Compliance (“FCC”) processes. * Support all control checks undertaken by FCC under the Operational Risk Framework (“ORF”) * Propose control enhancements and simplifications * Provide resources to support work by Segments and Product/FCC/Governance/Sanctions/ABC to upgrade business controls * Generate and monitor all metrics required for tracking operational performance of controls Head, CDD Controls Responsibilities * Undertake country CDD review activity executed in the regional CDD CoE * Review Politically Exposed Persons (“PEP”) files and sensitive client files * Integrate data across processes managed in Controls relevant to the CDD review * Escalate issues requiring business rejection/restriction * Work with Segments and Product Financial Crime Compliance (“FCC”) to escalate issues appropriately with the business at a portfolio level Leadership and Management * Implement and cascade the Group’s policy, framework and procedures to country level * Provide leadership to the Country FCC network as part of the Country FCC management team * Manage outsourcing arrangements where applicable, for example FCC processes hubbed to the Group’s Shared Services Centre * Lead or influence significant programmes of work in support of the financial crime compliance objectives * Assist in the development of an effective internal compliance culture by promoting the benefits of ethical business conduct and the benefits of compliance Knowledge Development and Information Management * Identify and communicate, across the business within the region, relevant changes in Controls policies, procedures and practices – recommending amendments as required * Assist in developing FCC Controls-related training to ensure the business and support units are provided with appropriate training Stakeholders Relations * Partner closely with the Regional FCC Controls and their teams, ensuring there is a consistent message to country FCC, and dealing with country issues as they come up * Support Country Compliance and FCC teams in managing regulatory relationships where FCC issues are a problemCompetencies * Partner with the business to make decisions based on the knowledge and interpretation of current and possible future policies, practices, trends and information of financial crime * Develop and implement financial crime compliance arrangements/frameworks (programs, policies and procedures) for bank and business lines * Develop and implement risk and Market Integrity methodologies * Deliver effective FCC/Sanctions/AML/ABC training programs to meet the training needs of the business * Implement prevention and detection client due diligence (CDD, EDD and CIP) to verify the identity of clients * Implement FCC/sanctions/AML/ABC risks identification and assessment and advise business on the findings * Resolve suspicious activity alerts (SARs) * Partner with Business and Operational Risk to identify and mitigate financial compliance risks * Conclude investigations of non-compliant activities * Review system safeguards and recommend process enhancements * Participate in regulatory and supervisory meetings and consultations * Resolve conflicts of interest arising from regulations and information security * Partner with regulators locally or globally Additional * The role holder needs to possess extensive knowledge of the laws and regulations applicable to money laundering, such as MLPA, the Patriot Act, OFAC/HMT requirements and Suspicious Activity Reporting requirements
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