| Purpose: |
The Senior AML Investigator will To support the Bank's Financial Crime Compliance Americas division (FCC) in ensuring that the business in the US operates in accordance with all legal and regulatory requirements and all Group standards relating to anti-money laundering and counter terrorism financing (AML). This role will conduct investigations that detect and report suspicious activity to governmental authorities and enable the Bank to form sound judgments concerning reputational and other risks and meet expectations of regulators and other compliance stakeholders.
Key Roles and Responsibilities
Identifying, researching and reporting suspicious activity. Managing the investigative process from initial detection to disposition. Thoroughly and timely reviewing reports and other investigative leads that potentially identify suspicious activity. Formulating and recommending responses to potentially suspicious findings, reporting such activity to the appropriate regulatory authorities, and supporting FCC in developing the Bank's forward-looking risk-mitigation program.
- Plan, lead and conduct AML investigations for potential suspicious activity, including those generated from detection scenario processes, the service of subpoenas and warrants, negative media reports, as well as other sources.
- Provide leadership, guidance and direction to the FCC Investigation Unit's AML Investigators through close-collaboration and supervision as well as cyclic Case Reviews, with a focus on these areas:
People and Talent (Responsibilities related to people and talent matters)
- Support Investigation Group Managers in oversight of AML investigations.
- Coordinate responses and requests pursuant to Section 314 of the USA PATRIOT Act.
- Provide guidance, direction, and assistance to Senior Investigators, Investigators and other team members in determining whether to close cases, escalate findings and/or file a Suspicious Activity Report ("SAR") with the U.S. Treasury's Financial Crimes Enforcement Network.
- Drafting and reviewing SARs.
- Conduct AML investigations with respect to matters presenting heightened complexity, sensitivity and risk.
- Supervise work of other team members to ensure completeness and quality of investigations, and to support quality assurance of investigative documentation.
- Oversee data-entry related to tracking and documenting all investigative steps.
- Assist Investigation Group Managers with administrative responsibilities for direct reports.
- Support the Investigation Unit's internal training program by providing subject-matter expertise to program development, administration and learning delivery.
- Support Investigation Group Managers in the effective engagement of FCC management, internal audit and quality-assurance staff, and regulators, concerning the FCC AML program.
Risk Management (Responsibilities Under Risk Management Framework - both execution and supervisory)
- Lead and develop an effective team through communication, performance management, development plans and reward/recognition practices.
- Promote an environment that supports diversity and reflects SCB core values.
- Understand technical aspects of systems relevant to CDD, Client Risk Assessments, Name and Transaction Screening, AML Monitoring and Case Management [EDIT IF REQUIRED].
- Ensure that detection scenarios that are developed and deployed are fit-for-purpose.
- Apply Group and FCC policies and processes (AML surveillance, client screening, risk assessment) to manage risks.
- Make recommendations (and/or implement) to relevant stakeholders on possible risk management responses to identified risks and/or findings of concerns from investigations.
- Assess risks arising from products / segments / geographies / customers / transactions.
- Inform senior management and relevant regulators of serious regulatory breaches (or where risk tolerances have been breached) and ensure that actions are taken quickly to remediate and/or activities are ceased.
- Analyse significant financial crime risk events (e.g. SAR's, non-compliant transactions, production orders) to ensure that all connected parties, particularly cross-border are identified and reported at the appropriate levels internally as well as externally across all relevant jurisdictions.
- Identify intelligence for typology studies and risk mitigation plans.
- Identify financial crime risk indicators through various internal/external sources that impact SCB and its clients.
- Provide investigative expertise to support management of Significant Regulatory/Legal cases.
- Conduct a root cause analysis on the control/other failures to ensure lessons are learned across the bank.
- Provide intelligence (to internal forums) on specific clients, client-types and emerging risk typologies.
- Provide intelligence inputs to support calibration of bank's Risk Methodologies (including aggregate client risk, product risk and country risk assessments).
Regulatory & Business conduct
- Awareness and understanding of the regulatory framework in which the firm operates, and the regulatory requirements and expectations relevant to the role
- Deliver 'effective governance'; challenge fellow executives effectively; and work with any local regulators in an open and cooperative manner .
- Display exemplary conduct and live by the Group's Values and Code of Conduct.
- Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct, across Standard Chartered Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.
- Lead the team to achieve the outcomes set out in the Bank's Conduct Principles: Fair Outcomes for Clients; Effective Operation of Financial Markets; Financial Crime Prevention; The Right Environment
- Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.
- Head, FCC Controls, Americas
- Head, FCC Investigations, Americas
- FCC Investigations Team Leads, Americas
- SCB Americas Audit, Operational Risk, L&C and SRP departments
- FCC Department in region and globally
- Embed Here for good and Group's brand and values in [country / business unit / team]
- Perform other responsibilities assigned under Group, Country, Business or Functional policies and procedures.
Qualifications and Skills
Leadership Level: Please choose the leadership level (e.g., Organisation Leader) after reviewing the Leadership Competency Framework
Take the Lead
Target Proficiency Level: Please choose proficiency level based on definition in the Competency Framework (Entry, Core, Advanced or Expert)
Compliance Policies and Standards
Compliance Review and FCC Assurance
Surveillance (including Screening and Monitoring)
Compliance Risk Assessment