Head; Financial Crime Compliance
NMB Bank Plc
Dar es Salaam
Job Location :Head Office
Responsible for setting strategic direction on financial crime risk management framework for the bank, and in steering the development, implementation, and monitoring of progress against a set strategy to manage financial crime risks within appetite to avoid material financial and reputational damage and protect clients’ money and assets.
Responsible for the development, implementation, and maintenance of an effective tactical and strategic financial crime compliance program necessary to support and protect the business against financial crime risks (i.e., money laundering, terrorist financing, bribery and corruption, fraud and sanctions) and related reputational risks.
As a designated Money Laundering Reporting Officer (MLRO), the Head of Financial Crime Compliance (FCC) is responsible for conducting investigations into suspected and known money laundering, terrorist financing and other similar irregularities in a professional and cost-effective manner and report suspicious transactions (STRs) to the Financial Intelligence Unit (FIU).
Set and implement the FCC vision and strategy consistent with the department’s vision and strategy in support of the bank’s strategic direction and growth aspirations.
Ensure that there is adequate support (people, processes, tools, frameworks, systems) in the Unit for necessary FCC deliverables.
Promote the culture and practice of compliance with the bank’s policies and standards (including conducting business within regulatory and policies’ requirements and to high ethical standards) and embed the bank’s Code of Conduct.
Ensure key changes to FCC related laws, rules and regulations are timely communicated and cascaded to the respective businesses / functions.
Build and maintain an effective and constructive relationship with businesses and functional stakeholders that is based on trust, capability and integrity, providing timely, responsive and quality FCC related advice and guidance to enable the bank to meet its strategic objectives.
Provide advice, analysis (and challenge when appropriate) to the business, including product design, new business initiatives, remedial activities, and transactional advice.
Support relevant stakeholders to make decisions based on current and possible future policies, practices, and trends, and provide robust challenge to all relevant business and functions stakeholders where activities are outside of risk tolerance / appetite.
Keep track of and provide advice to relevant stakeholders on the interpretation and application of regulatory expectations, laws, best practices, and FCC policies.
Provide formal training on financial crime risk (anti-money laundering (AML), anti-bribery & corruption (ABC), fraud and sanctions) to all relevant employees.
Proactively monitor regulatory developments to manage the regulatory impact on the bank’s business and its operations and flagging any potential hotspots and risks.
Act as a center of expertise, providing regulatory advice and recommendations on financial crime risk issues / matters.
Develop, keep up-to-date and recommend for approval by the relevant Management / Board Committee, appropriate policies, processes and manuals to address financial crime risks, aligning with the relevant regulatory requirements.
Provide governance and oversight on implementation of FCC policies, procedures and processes (AML surveillance, client screening, risk assessments, etc.) to manage FC risks.
Within the bank’s Enterprise Risk Management Framework, establish and maintain appropriate risk-based compliance framework for identifying, assessing, managing, mitigating and reporting financial crime risks across the bank.
Identify and assess sources of financial crime risks and ensure that system and controls are appropriate to mitigate and manage risks within acceptable risk tolerance levels.
Understand the technical aspects of system relevant to CDD, Client Risk Assessments, Name and Transactions Screening, Transactions Monitoring and Case Management.
Drive and lead continuous discussions to support revisions / fine tuning of the AML and fraud transaction monitoring rules to ensure alignment with the evolving risk profile.
Establish and maintain watchlists used for customer and transactions screening and various other due diligence and investigative purposes.
Make recommendations (and /or implement) to relevant stakeholders on possible risk management responses to identified risks and /or findings of concerns from investigations.
Anticipate horizon risks in the area of financial crime that may have a significant impact on the bank and develop effective strategies to mitigate such horizon risks.
Conduct money laundering, terrorist financing and proliferation financing risk assessments and oversee the review and analysis of the client base to identify and manage risk clients.
Design and monitor programs designed to detect, investigate, and report potentially suspicious transactions, fraud, and other possible violations of laws, regulations, policies, and/or procedures. Keep an updated register of STRs and fraud cases.
Provide intelligence on specific clients, client types and emerging risk typologies to support calibration of the bank’s risk methodologies.
Collect and collate intelligence information on the current trend and typologies of frauds and advise management on the risk mitigation plans.
Attend relevant leadership meetings and provide relevant reports to senior management and governance / risk committees.
Ensure tracking and remediation of financial crime risk related regulatory findings.
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.
Prepare and cascade lessons learned from audit findings, FCC assurance activities and specific investigations.
Track significant issues arising from FCC metrics, assurance activities, audit reviews and regulatory inspections, proving validation of issue closure where necessary.
Propose control improvements, enhancements and simplifications where appropriate.
Be accountable for identification and escalation of potential FC risks and issues to senior management through appropriate governance channels.
Collect, analyze and interpret data in reports to senior management and relevant governance / risk committees.
Analyze and interpret data to produce reports that help the bank identify and manage emerging areas of financial crime risk / vulnerability and thus drive the relevant remediation actions.
Ensure that all activity and transactions that are identified as potentially suspicious are investigated and reported to the Financial Intelligence Unit (FIU), where applicable.
Interact with law enforcement and other outside entities regarding loss recovery including court ordered restitution.
Liaison with national / international law enforcement agencies and financial industry representatives to proactively identify financial crime trends and organized criminal attacks for development and implementation of appropriate mitigation control measures.
Build trust through meeting regulatory commitments and having regular briefings / engagements with regulators.
Drive proactive engagement in regulatory reform, including ensuring identification and escalation of regulatory reform proposals, participation in internal regulatory reform forums and memberships of external industry forums.
People & Talent
Promote and embed a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is a norm.
Lead through example and build the appropriate culture and values. Set appropriate tone and expectations from the team and work in collaboration with risk and control partners.
Assess capability and skills of the team on an ongoing basis to ensure alignment of skill set to the risk management demand of the business.
Support the provision of ongoing training and development of people and ensure that holders of all critical functions are competent, suitably skilled and qualified for their roles ensuring that they have effective supervision in place to mitigate any risks.
Provide leadership, management and coaching to direct reports to ensure are highly engaged and performing to their potential.
Ensure direct reports have clearly articulated and well understood roles and responsibilities through meaningful and accurate job descriptions.
Projects / Change Management
Accountable for key FCC change programmes.
Maintain workplans specific to FCC projects / initiatives and communicate the same to stakeholders in a regular and timely fashion to inform and seek inputs.
Drive and stimulate an environment where forward planning, prioritization and deadline management lead to efficient work practices and streamlined functional activities and processes.
Knowledge and Skills:
Good understanding and appreciation of compliance risk management practices.
Good knowledge and understanding of applicable regulatory requirements and banking laws.
Good understanding of current and anticipated regulatory environment requirements and supervisory expectations.
Strong analytical skills and confidence in interrogating data, processes, and interviewing stakeholders.
Able to interpret and communicate clearly to the business the application of relevant rules and regulations.
Personal authority, integrity and ethics, with proven ability to establish relationships and exert influence at senior levels both internally and externally.
Takes responsibility, ownership and accountability for own tasks and work output.
Proactive and creative approach to work, self-motivated and pragmatic.
Sharp business acumen, including the ability to assess risks.
Ability to communicate effectively, orally and in writing, with senior internal and external audiences – to educate, persuade, negotiate, gain decisions, enforce.
Strong leadership qualities, excellent inter-personal skills, and multi-cultural awareness.
Qualifications and Experience:
Bachelor’s degree or its equivalent in Law / Banking / Economics / Finance or related qualifications
Any additional relevant financial crime compliance related professional certifications will be an added advantage.
At least 10 years of experience in Risk management, Governance, Compliance, Financial Crime compliance especially in conducting financial crime related investigations, including frauds.
Minimum of 5 years in a leadership / managerial position.
Experience in designing and implementing programs, policies, and procedures that will ensure compliance with local and international standards and best practices.
Head; Financial Crime Compliance Job Opportunity at NMB Bank Plc
NMB Bank Plc is committed to creating a diverse environment and is proud to be an equal opportunity employer
Job closing date : 20-Jan-2023