Head of Financial Crime Control

Sanderson Recruitment Plc
75000.00 - 90000.00 GBP Annual + Excellent Benefits
17 Mar 2017
25 Mar 2017
Contract Type
Full Time

Head of Financial Crime Control

A well known and reputable financial services organisation is currently looking for the head of financial crime control position in Edinburgh on a permanent basis paying between GBP75,000-90,000 depending on experience.

In this role you will set the strategy and lead the planning and delivery of all 1st line Financial Crime accountabilities and lead the 1st Line Financial Crime function. You will support the development and maintenance of a compliant, proportionate and effective Financial Crime framework across the Bank.

I am looking for a subject matter expert in Fraud, AML, Sanctions or Anti-bribery with solid professional experience of working in or supporting the Financial Services sector.

You'll lead 1st Line strategy, planning and delivery in respect of:

  • Policy, standards & procedures

- Primary point of contact on local application/interpretation of the Bank's Financial Crime Policy and standards
- Submitting requests for waivers or exceptions to policy for approval by 2nd line

  • Risk assessment

- Coordinating the delivery of the annual FC risk assessment
- Designing and operating a customer risk assessment strategy based on criteria agreed with 2nd line FC team AML/SANCTIONS related suspicions and Legal Orders relating to Financial Crime
- Reviewing sanctions screening referrals and subsequent investigation, decisioning and disclosure
- Deciding on which clients, accounts or payments to exit/freeze in relation to AML/SANCTIONS risk. Subsequently undertaking control testing to ensure client has been exited by the business
- Central receipt and coordination of appropriate action on all FC related legal orders
Transaction Monitoring, Sanctions screening and fraud detection/investigation/recovery
- Owner of all transaction monitoring, sanctions/PEP screening, verification of identity and fraud detection systems
- Joint sign off/approval (with 2nd Line FC) of initial design and any proposed changes to FC system rules or settings
- Maintaining central records of system rules, lists, settings and all changes to the Bank's TM or screening/filtering rules, and supporting rationale + governance
- On-going review of AML/Sanctions system referrals to identify potential gaps or tuning opportunities. Full ownership of the Fraud rules review/analytics process
- Horizon scanning (and data analysis) to identify new/emerging FC threats
- Joint oversight (along with 2nd Line FC, and where appropriate Supply chain management) of the conduct of internal fraud/malpractice investigations
- Acting as central reporting point, for all reports of potential internal fraud against the bank or customers. Subsequently ensuring that key stakeholders are engaged and that investigation oversight, reporting arrangements are in place and that corrective actions are taken to prevent recurrence

  • Customer Due Diligence and Enhanced Due Diligence

- Reviewing of PEP screening referrals, confirmation of PEP matches and 1st line approval to on-board or retain newly identified PEPs or customers meeting the higher risk criteria.
- Tracking completion of EDD and enhanced monitoring to higher risk/PEP customers, as identified by the Nominated officer function
- Managing financial crime, sanctions and terrorist financing related exits

  • Compliant change management and Remediation

- 1st line FC sign-off of all new products or delivery channels
- 1st line approval of all FC related remedial activity

  • Training

- Ownership and completion of the annual FC training plan
- Annual review and approval of FC related training material

Key Skills required:

  • Extensive experience in Management/SME advisory/consulting/legal experience in one of more of the following:

- 1st or 2nd Line Financial Crime function, within a Financial Services environment
- Specialist 3rd line Financial Services audit function, specialising in Financial Crime Audit
- Specialist Financial Crime consulting firm

  • Previous experience as a nominated officer or SMF 17/CF-11, or deputy MLRO/appointed alternate to Nominated Officer is desirable
  • Professional experience of either directly working in, or working in support the Financial Services Sector - Retail Banking experience preferred but not essential
  • Detailed working knowledge of relevant FC Legislation, approved guidance, Regulatory Guidance and industry good practice
  • Strong relationship management and inter-personal skills
  • Proven leader and facilitator/consensus builder across teams and in a Matrix management organisation
  • Resilience and the ability to influence and operate at all levels within a financial services firm, including at a Senior Management and Executive level
  • Strong awareness of the control and regulatory environment within a financial services organisation

If this role sounds ideal for your skills and experience and you could be successful in this role please apply now for immediate consideration.