AVP FCC Sanctions Policy, Governance and Advisory : 00008QKJ
Employment Type: Regular
This position is a strategic risk management leadership role, responsible for the overall oversight and management of Policy, Advisory and Investigations Teams across Canada to ensure all legislative and regulatory requirements under the Global Sanctions Policy and Canada Country Supplement (referred to hereinafter as “Policy”) are met and Sanctions risk across HSBC’s global lines of business is actively managed and mitigated. Role holder will lead Policy and Governance Team, Sanctions Advisory Team and Sanctions Investigations team within the region, working in conjunction with Regional Head of Sanctions reporting up to Global Head of Sanctions
Principal Accountabilities: Key activities and decision making areas
Impact on the Business
The role holder is accountable for Canada compliance with Policy, and external Sanctions regulation applied through;
- Fulfilling and executing required regional level Policy management;
- Ensuring Policy implementation across region whilst effectively overseeing breaches, dispensations and procedures that are completed within teams
- Provide oversight and support to required country level regulatory engagement and reporting (internal and external);
- Fulfilling required regional level Sanctions subject matter expertise specifically relating to Policy Governance, Sanctions Advisory and True Match Investigations and assessment;
- Whilst effectively managing, identifying, mitigating and escalating Sanctions risk within region in a proactive and continuous manner;
- Whilst effectively driving the implementation of globally led Sanctions change initiatives within region
- Act as the Regional Head of Sanctions Officer in Charge when the RHS is on leave
Fulfilling required Regional level Policy management activities:
- Communicate and oversee the implementation and full adherence to Policy within region, including but not limited to the review of related Sanctions Guidance and Operating Procedures, and ensuring sanctions related regional FCC procedures, guidance and FIMs are fully aligned to the Global Sanctions Policy, up to date, accurate, and embedded within Canada
- Liaise with FIU, Regional Regulatory Affairs and Regional Legal to identify sanctions themes, trends and emerging legislation.
- Identify and respond to external regional trends and regulatory requirements which have a regional impact through the inception of regional changes to BAU
- Identify, impact assess and oversee regional compliance with Policy, global Sanctions regulatory changes and country level compliance with local regulatory changes
- Review and approval country supplements pertaining to Canada where required.
- Review and submission of Policy and Customer dispensations pertaining to <region> and countries within Canada
- Where identified escalate Sanctions breaches in the appropriate manner to the required escalation point and agree the remedial action plan with the relevant countries
- Review and submit to Regional Head of Sanctions approval for escalated customer and transaction risk approvals which require Sanctions approval and ensuring Global Sanctions are notified.
- Review and respond to escalated true matches, providing support to the respective country as required.
- Identify and maintain oversight of all potential breaches of Sanctions within Canada ensuring appropriate escalation to the Regional Head of Sanctions, Global Head Sanctions, Head of Sanctions (Business Line) and Regional Head of FCC as required
- Ensure Identify root cause, any associated trends, and resolve all Regional level actions remediating Policy breaches
- Oversee the identification and preparation of licensing requests at country level, providing support as necessary
- Provide and maintain intrusive scrutiny for all Policy events pertaining to Canada
- Oversee the communication and implementation of a Sanctions related records retention policy
- Maintain oversight of all country level records of Service Level Agreements (SLAs) pertaining to outsourced Sanctions activities or non-mandated screening systems, ratifying that all SLAs are fully compliant with Policy.
Fulfilling screening and alert investigation activities:
- Maintain Awareness of the adherence with the global Sanctions screening strategy into Canada, including evidence of country level implementation and the continual review and refinement of the strategy
- Periodically review the Sanctions standards with regards to investigation procedures, levels of fuzzy matching screening, risk based approaches, and quality assurance.
- Assist with maintaining oversight of customer sanctions screening solution at Regional level, in addition to any required local-non mandated sanctions screening systems
Fulfilling required regulatory engagement and all reporting (internal and external) activities:
- Provide the focal point for all regulatory sanctions matters and engagement relating to Policy & Governance, Advisory and True Match Investigations
- Engage with regulators and industry bodies at a regional level and maintain oversight of country level regulatory engagement providing support and guidance to country level FCC Sanctions community as necessary
- Oversee all mandated regulatory reporting obligations at a regional and country level with regards to customer activity, including but not limited to, annual reporting where required and regulatory voluntary disclosures, providing early sight of such activity to Global Head of Sanctions as required
- Ensure availability and retention of accurate and comprehensive Sanctions related MI to the agreed standard form across the region at country and regional level (split by global business line) for reporting to external authorities and regulators, relevant business forums and committees
- Analyze collated Regional MI to identify trends, anomalies and potential process improvements to continually improve the management and mitigation of Sanctions risk within Canada
- Attend Regional Sanction Executive Committee
- Attend and provide regional specific updates to the Global Sanctions Executive Committee and all other identified relevant regional level FCC committees as required
- Represent the FCC Sanctions function at all identified relevant regional level business committees as required.
Fulfilling required sanctions subject matter expertise and assessment activities:
- Provide subject matter expertise to the business units within Global Business Lines
- Guide and oversee the provision of annual requirements to regional FCC Education to ensure the specific training needs of the Sanctions community and needs of the wider FCC function and First Line of Defense at country and regional level are met
- Responsible for providing regional oversight to the annual enterprise wide risk assessment completion and submit to the Regional Head of Sanctions.
- Advise the business on specific risks associated with prospective business, products and service and recommend mitigation controls and strategies as appropriate
- Implement, manage and provide functional leadership to a regional advisory function
Customers / Stakeholders
First line of Defense;
- Build and maintain strong partnership with global line of business to effectively drive and accelerate the execution of FCC Sanctions change program across the region
- Challenge and identify any potential Sanctions risk inherent in global line of business decisions and client activity
- Provide expertise and support on escalated Sanctions related matters with particular details to Policy & Governance, Advisory and True Match Investigations
- Respond to escalations specific to Sanctions risk associated with prospective business, products and service, working with Sanctions Line of Business leads to design mitigation controls and strategies as appropriate across the region
FCC Function/second line of defense
- Lead/liaise with relevant stakeholders within Global FCC, Regional FCC, and Country FCC teams to provide expertise and support on all regional level Sanctions related matters
- Support the regional Head of FCC in the provision of Regional Policy & Governance, Advisory and True Match Investigations information on Sanctions issues
- Work collegiately with the FCC Monitoring & Testing function, and FCC Assurance to ensure effective deployment of agreed regional testing strategies, providing regional/country support as necessary
- Support the Global Head of Sanctions in the provision of reports for Canada and constituent countries to the Board (and, as necessary, regulators) on Sanctions related issues
Third line of Defense
- Work collegiately with Internal Audit to ensure effective deployment of agreed regional audit strategies, providing regional/country support as necessary
- Provide support and oversight on the remediation of all Sanctions related Audit findings relating to Canada. Role holder will need to retain ownership of Audit actions relating specifically to Regional Policy, Advisory and Investigations Teams
- Participate in and work with relevant industry bodies and groups in relation to Sanctions related initiatives, trends and proposals
- Ensure that the Group’s interests are externally represented and professional and positive relationships are fostered at a regional level
- Deliver fair outcomes for our customers and ensure own conduct maintains the orderly and transparent operation of financial markets.
Leadership & Teamwork
- Owner of the organization structure for the Sanctions function at a Regional Policy, Advisory and Investigations level, implementing a change control mechanism to provide regional approve and communication to Global Head of Sanctions of all amendments to approved structure (including any changes to approved level of multi-hatting)
- Provide approval to the hire or appointment of any team members within Policy & Governance, Advisory and True Match Investigations Team ensuring all appointments or resignations are notified to the Global Head of Sanctions.
- Deliver the global strategy for the FCC Sanctions function into the Regional Policy & Governance, Advisory and True Match Investigations Team
- Lead, motivate and develop an effective Regional team through communication, cultivating an environment that supports diversity, reflects the HSBC brand and improves employee engagement
- Ensure development activities are a core priority and enable all team members to take reasonable time for learning and developmental activities.
- Maintain and develop positive and professional working relationships with senior business managers at the Regional/Country/ Business line levels.
- Foster positive and professional working relationships within FCC and other senior managers throughout the Group.
- Ensure the management of resources, people, process and change management to support a customer/commercially focused FCC function
- Work as a key member of the FCC team to drive and accelerate the embedding of the Financial Crime Compliance change program within Canada
- Promote an environment that supports diversity and reflects the HSBC brand.
Operational Effectiveness & Control
- Provide regional solutions to complex global issues/initiatives in an ever changing, high-risk environment.
- Approve the schedule for, and oversee, the monitoring of the implementation of FCC Sanctions controls
- Monitor and assess performance and the level of resourcing, costs and spend of the team
- Ensure all DIMs, BIMs, regional and country procedures are updated as necessary following changes in Policy and/or Country Supplements
- Maintain awareness of operational risk within assigned portfolio and minimize the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting
- Maintain and observe all HSBC control standards including the timely implementation of recommendations made by internal/external auditors and external regulators
- Ensure that all employees are aware of and effectively identify and manage applicable money laundering (ML), terrorist financing (TF), sanctions and reputational risks.
- Complete other responsibilities, as assigned.
- The role holder is required to work closely with the Country Leads and staff within the country to provide a level of support in the respect of Operation Effectiveness. Ensuring that both internal and external departments are aware and adhering to SLA’s and assisting with the provisioning of system licenses. The nature of the role requires close working contact with managers across the Region and specific Country Heads of Sanctions and across the wider HSBC Group.
Management of Risk
- Ensure compliance of both general and anti-money laundering and anti-terrorist financing (AML/ATF) compliance controls as well as operational risk controls in accordance with HSBC or regulatory standards and policies; and optimize relations with regulators by addressing any issues.
- The jobholder is responsible for ensuring that the FCC Sanctions standards in each country where HSBC operates in Canada are in accordance with the Policy (subject to any globally approved local supplements/dispensations) and that the Sanctions Policy aspects of the Risk FIM are effective and relevant
- Provides support in managing Sanctions risk for HSBC Canada; Supports businesses and functions to address any actual and potential Sanctions compliance issues.
- The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organization.
- This will be achieved by consistently displaying the behaviors that form part of the HSBC Values and culture and adhering to HSBC risk policies and procedures, including notification and escalation of any concerns and taking required action in relation to points raised by audit and/or external regulators.
- The jobholder is responsible for managing and mitigating operational risks in their day to day operations. In executing these responsibilities, the Group has adopted risk management and internal control structure referred to as the ‘Three Lines of Defense’. The jobholder should ensure they understand their position within the Three Lines of Defense, and act accordingly in line with operational risk policy, escalating in a timely manner where they are unsure of actions required.
- Through the implementation the Global AML, Sanctions and ABC Policies, supporting Guidance, and Line of Business Procedures the jobholder will make informed decisions in accordance with the core principles of HSBC’s Financial Crime Risk Appetite.
Observation of Internal Controls
- Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.
- Jobholder is an ‘insider’ for dealing purposes and subject to strict controls and confidentiality.
- Jobholder is required to assist Regional Head of Sanctions in managing responses to adverse compliance metrics, including unsatisfactory FCC Reviews and Audit reports
- This will be achieved by adhering to all relevant processes/procedures and by liaising with Financial Crime Compliance department about new business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimizing relations with regulators.
- The jobholder will also adhere to and be able to demonstrate adherence to internal controls. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators.
- Seasoned risk professional with experience in one or more senior risk compliance roles, including Sanctions
- Extensive knowledge of Sanctions regulations and guidance
- Strong understanding of Global Business Lines, its strategy, business drivers and its products
- Significant experience in the financial services industry
- Lateral thinker with an ability to interpret and solve complex issues
- Well-developed leadership skills
- High level of English written and verbal language skills
- Excellent communicator with strong inter-personal and influencing skills
- Experience in leading assurance work in a complementary discipline e.g. Audit would be an advantage
- Ability to lead change, contributing to joining up with the other teams in Risk and Business globally
- Experience of dealing with regulatory matters and confident interaction with Regulators
- Ability to develop practical, cost effective solutions to complex issues
Job Field : Risk Management
Primary Location : North America-Canada-British Columbia-Burnaby
Schedule : Full-time Shift : Day Job
Type of Vacancy : Country vacancy
Job Posting : 06-Feb-2017, 20:37:48 Unposting Date : 16-Feb-2017, 02:59:00