Standard Chartered Bank Nigeria -  At the core of the Group's people strategy is our focus on employee engagement. Engagement is a key driver of productivity and performance, which creates the foundation of our performance culture.

POSITION : Senior Manager FCC, Trade

Descriptions

The role holder provides thought leadership regarding the identification and mitigation of financial crime risk affecting the Trade business in his or her country.

The role holder provides product specific financial crime risk support to the Trade business and Trade Operations and provides his or her Trade experience to Local FCC (in his or her country) where needed. The role holder is a key resource in the roll out and day-to-day management of the Trade AML program in their country and participates actively in the assessment of escalated cases.

The role holder also regularly participates in global discussions and calls with other FCC, Trade experts around Trade Based Money Laundering (TBML) and other trade-based financial crime. 

Responsibilities 
Advisory Role:

• Provides advice to the Trade business, which includes Trade Operations, regarding financial crime risks and controls.
• Reviews new Trade products and initiatives and recommends solutions to address any risks.
• Reviews existing Trade products against the FCC Global Product Risk Assessment and recommends solutions to address any risks.
• Provides guidance to relevant jurisdictions in preparation for a Trade financial crime risk regulatory inspection.
• Is the subject matter expert in cases escalated by AML Advisors to Country FCC (level 3) for assessment and possible escalation to authorities.

Controls development and implementation:

• Is the local representative for FCC for the local roll outs of the Trade AML Target Operating Model and provides all necessary support from an FCC perspective to ensure a successful roll-out.
• Reviews existing financial crime risk controls in Trade to determine their adequacy.
• Proposes new/revisions to existing controls to incorporate changes to industry best practice and regulatory expectations.
• Works collaboratively with the business and Operational Risk in the B/LKCSA process for financial crime risk.
• Ensures appropriate documentation of controls and control decisions.

Training:

• Helps maintain an effective financial crime risk training and awareness programme using different modes of delivery for Trade.
• Provides ad-hoc additional training as and when appropriate.
• Supports trainings and workshops in his or her region specifically tailored around TBML.
• Assists in developing new trainings and provides case material based on experience.

Monitoring/Reporting:

• Performs an annual risk assessment and develops and implements Compliance monitoring in conjunction with relevant stakeholders.
• Prepares reports for senior management in the region and for Global FCC when required.
• Monitors completion of mandatory training and tests financial crime risk awareness within Trade.
• Ensures timely escalation of incidents, control breaches to relevant stakeholders, assists in preparation of Suspicious Activity Reports (SAR’s) when needed.
• Performs quality assurance review of Trade Operations’ decisions in relation to potentially suspicious activity.

Partnership:

• Builds relationships with relevant stakeholders in the business, in the L&C organisation, and in other risk functions.
• Endeavours to keep all relationships on a strong professional and collegial footing.
• Endeavours to take a holistic approach to the management of risk – the financial crime risk issue may not be the most pressing risk issue.

Knowledge Development and Information Management:

• Participate proactively in various information streams to gather appropriate knowledge on industry developments and regulatory developments.
• Ensure provision of appropriate FCC Trade awareness through the regional training managers

Stakeholders Relations:

• Engage actively with relevant stakeholders - local teams, regulators, risk functions and compliance colleagues to continually value-add to the overall risk management framework
• Analyse and escalate FCC regulatory developments relating to  Trade and product to the Regional Head FCC Trade, AME.

Strategy:

• Provide input /Region/Country/Client Business operating model design of relevant FCC and business processes from an FCC Trade perspective.
• Support the Regional Head of FCC Trade, AME in implementing the vision, strategy, direction and leadership for the Region , consistent with the vision and strategy for FCC and in support of the Group’s strategic direction and growth aspirations.

Business:

• Analyse comprehensive impact of financial crime related Trade regulatory matters on the relevant business area and its operations.
• Support the Regional Head of FCC Trade, AME nsuring that key changes (to laws, rules, regulations) in relation to FCC Trade are communicated and cascaded in Country in coordination with group communications.
• Support relevant stakeholders to make decisions based on current and possible future policies, practices, and trends.
• Keep track of and provide advice to relevant stakeholders on the interpretation and application of regulatory expectations, laws, best practices and policies related to FCC Trade.
• Support resolution of competing requirements between regulationsfor example between AML regulations and data privacy/bank secrecy  or information security regulations.
• Provide advice to the Trade business, which includes Trade Operations, regarding financial crime risks and controls.
• Review new Trade products and initiatives and recommends solutions to address any risks.
• Review existing Trade products against the FCC Global Product Risk Assessment and recommends solutions to address any risks.
• Provide guidance to relevant jurisdictions in preparation for a Trade financial crime risk regulatory inspection.

Processes:

• In conjuction with the Regional Head of FCC Trade, AME develop, keep up to date and recommend for approval by the relevant Risk Committee, appropriate policies/processes/DOIs to address financial crime risks for FCC Trade, aligning with relevant regulatory requirements.
• Providing guidance and oversight over the implementation of FCC Trade -related policies and procedures in Region and Country to ensure compliance with such policies and procedures.
• Provide advice to relevant stakeholders on compliance with Group standards relating to FCC Trade.
• Act as (second line) Risk Control Owner under the Group’s Risk Management Framework for those aspects of Regulatory Compliance relating to FCC Trade, and escalate issues as appropriate.
• Review existing financial crime risk controls in Trade to determine their adequacy.
• Propose new/revisions to existing controls to incorporate changes to industry best practice and regulatory expectations in relation to FCC Trade.
• Work collaboratively with the business and Operational Risk in the B/LKCSA process for financial crime risk.  Ensure appropriate documentation of controls and control decisions.
• Where needed supports FCC teams in Country with trade specific cases that are escalated to FCC.

Risk Management:

• Understand technical aspects of systems relevant to Trade financial crime risk.
• Ensure that detection scenarios that are developed and deployed are fit-for-purpose.
• Collaborate with stakeholders and provide the requisite support to establish and maintain watch lists used for customer and transaction screening and various other due diligence and investigative purposes Regionally insofar as they relate to FCC Trade.
• Provide advice on the application of risk management frameworks (e.g. ORF, GRA) in relation to FCC Trade..
• 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.
• Anticipate horizon risks in the area of Trade-related financial crime that may have a significant impact on the Group and develop effective strategies to mitigate such horizon risks.
• Identify FCC Trade intelligence for typology studies and risk mitigation plans.
• Advise relevant stakeholders on outcomes of  risks identification and assessment methodologies from an FCC Trade perspective.
• Partner with legal counsels for advice on FCC Trade technical matters (as appropriate).
• 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.
• Oversee the review and analysis of the client base to identify and manage high risk clients, or specific country reviews.

Governance:

• Attend relevant leadership meetings.
• Ensure tracking and remediation of surveillance and investigations related regulatory findings.
• In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure senior management and relevant regulators are informed and that actions are taken quickly to remediate and/or activities are ceased.
• Prepare and cascade lessons learned from audit findings, FCC assurance activities and specific investigations.
• Track significant issues arising from FCC metrics, FCC Assurance activities, Audit reviews and regulatory inspections, providing validation of issue closure where necessary.
• Propose control improvements, enhancements and simplifications where appropriate.
• Be accountable for identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.
• Collate, analyse and interpret data in reports to senior management and relevant governance/risk committees.
• Analyse and interpret data to produce reports that help the bank identify and manage emerging areas of risk / vulnerability and thus drive remediation action within the FCC function.

Regulatory & Business Conduct:

• (The below is mandatory standard wording, do not remove)
• 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.
• Support the Trade AME 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.
• Represent the Group through relationships with key regulators, relevant industry and vendor / user groups.
• Support relevant stakeholders to respond to regulatory questions.

Project/Change Management:

• Lead or influence significant programmes of work in support of the financial crime compliance objectives.
• Review new business requirements and provide solutions where required.
• Manage and protect business as usual (BAU) capability during change programmes, as well as during the execution and delivery of the Remediation initiatives through project phase and into BAU.

Qualifications 

• Possess core technical knowledge of the Trade Business with a sound practical background in any of the Trade areas of Front Office, Product Management, Operations or Risk Management of atleast 10 years.
• Possess core technical knowledge of Trade related financial crime risk typologies and controls.
• Minimum of a second class degree from a reputable university.