Director, Compliance Advisory, Transaction Services (Correspondent Banking)

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Job Summary Primary day to day 2LoD advisory, oversight and challenge in the Correspondent Banking Advisory space as reflected in strategy below. Incumbent is fungible across wider ranging responsibilities (as set forth in this JD) of the CFCR Client Coverage (CC), Transaction Services (TS), Global Banking & Functions Advisory Team.
In addition to Correspondent Banking risk management, will lead day to day management of the Customer Due Diligence (CDD) Risk Framework including where applicable, oversight and challenge of the 1LoD KYC function:

• KYC Policy and Standards development, including Country Addenda
• CDD and EDD activities (all inclusive) as executed by Branch and Group first line and Group second line
• DDA Working Group prospective client pipeline and submission
• Responsible for updating and developing Customer Due Diligence (CDD) policies and standards, including country specific regulations

Key Responsibilities Strategy

• Contribute materially towards the implementation of the vision, strategy and direction of the CIB CC, TS, GB & Functions Advisory team. Contributions should be consistent with the Americas Head, CFCR Advisory, CIB CC, TS, GB & Functions vision and strategy for the team and the strategy of the CFCR function as a whole; both in support of the Bank's strategic direction and growth aspirations.
• Continue to improve the Group's approach towards reducing regulatory and financial crime risks throughout the Americas CIB Client Coverage client lifecycle (from on-boarding to off-boarding) to protect the reputation of the Group and to avoid significant financial loss.
• Initiate and contribute to the overall risk and control enhancements to the Correspondent Banking program for SCB Americas, and where requested, Transaction Services and Client Coverage.

Business

• Develop a comprehensive foundational understanding of the business model and strategy in order to provide substantive required oversight support and challenge in order to enable appropriate and sustainable CFCR outcomes.
• Build and maintain an effective and constructive relationship with all key business and functional stakeholders that is based on trust, capability and integrity, providing timely, responsive and quality advice and guidance to enable the business and functions to meet/ achieve their strategic tactical objectives.
• Provide robust challenge to senior management and all relevant business stakeholders where activities are outside risk tolerance/ appetite, escalating as necessary, until appropriate oversight and ownership is achieved including actions and plans to address any remedial action needed to come back within risk tolerance/ appetite.
• Provide and communicate timely CFCR- related advice, analysis (and challenge when appropriate) in relation to CIB Client Coverage and Transaction Services including product design through to post sale reviews / assessments, new business initiatives, bespoke projects, remedial activities (including nature, scale and rigour of past business reviews), and transactional advice.
• Support the maintenance of global CFCR standards in accordance with standards set by senior management.
• Support the maintenance and refresh of relevant CFCR frameworks applicable to CIB Client Coverage and Transaction Services.
• Support the implementation of the SPOC-COE model. This includes (but not limited to): taking ownership of incoming queries by not handing them off, taking a leading role in actively becoming the go-to person for the business/function and ensuring advice provided is consistent throughout CFCR Advisory in relation to CIB Client Coverage, Transaction Services.
• Support a risk-based assessment of the Correspondent Bank portfolio focusing both on individual client and aggregate risk e.g., by client type, by market etc.
• Support prioritization of client reviews based on risk parameters.
• Support the implementation of a local Correspondent Banking control framework, including policy development as required; propose new/revisions to existing controls to incorporate changes to industry best practice and regulatory expectations.

Processes

• Drive the governance and oversight over the implementation of CFCR- related policies and procedures with respect to CIB Client Coverage, Transaction Services (to enable compliance with such policies and procedures).
• Support efforts to establish and maintain effective processes (including training, advice and support) to ensure that policies and standards to address CFCR risk are effectively implemented across CIB Client Coverage, Transaction Banking.
• Support the provision of second line challenge to processes owned by CIB Client Coverage, Transaction Services.
• Develop and maintain effective policies/processes/DOIs, where required and/or deemed necessary (including training, advice and support) to address CFCR risks across CIB Client Coverage, Transaction Services, aligning with relevant regulatory requirements.
• Provide support and challenge to the relevant Business stakeholders e.g. COO teams to ensure that they establish and monitor appropriate processes for compliance with CFCR policies and standards (including meeting regulatory obligations and maintaining high standards of conduct).
• Support and/or perform analysis on individual clients to understand thematic risks, strength of their control environment, underlying client base and level of risk; this includes reviews of Suspicious Activity Reports (SARs) and other risk metrics and data as appropriate
• Recommend ways of mitigating risk and collaborate with business management, FI RRM teams and Global Account Managers to implement mitigants and controls
• Drive, and chair where appropriate, working groups focusing on elements of the Correspondent Banking control and governance framework, including support for the KRI Working Group and the US Correspondent Banking Oversight Group to ensure focused discussion and action on key areas
• Work closely with the global Correspondent Banking Due Diligence team to ensure that key clients are prioritized appropriately and that US based risk factors are understood and appropriate mitigants are identified
• Participate in select client reviews, including potential client visits (both at client site and on site at SCB), on a risk priority basis
• Perform ad hoc special reviews or projects as advised by the Americas Head, CFCR Advisory, CIB Client Coverage, Transaction Services, Global Banking & Functions.
• Monitor and identify industry developments to ensure industry best practice
• Contribute materials and support agenda items at the US Correspondent Bank Operating Group
• Ensure appropriate documentation of controls and control decisions
• Support and contribute to development of trainings and workshops in region specifically tailored around Correspondent Banking financial crime risk
• Support an annual risk assessment of Correspondent Banking, working with the FCC Risk Assessment team and business management
• Prepare reports for senior management in the region and for Global FCC when required.
• Ensure timely escalation of incidents, control breaches and other matters to relevant stakeholders as required.

People & Talent

• Role model and assist the Americas Head of CFCR Advisory, CIB Client Coverage, Transaction Services, Global Banking & Functions to build the appropriate culture and values. Set appropriate tone and expectations within the team and work in collaboration with risk and control partners.
• Contribute to promoting and embedding a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm.
• Contribute to instilling an environment where forward planning, prioritisation, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm.
• Assist in the provision of ongoing training and development to ensure that team members are competent, suitably skilled and qualified for their roles.
• Provide constructive developmental feedback at business, function, country and individual level as appropriate, on CFCR matters.
• Contribute materially towards the migration of skill, knowledge, best practice and lesson learned across the network between CFCR Advisory and Centre of Expertise colleagues especially in relation to legal/regulatory risks and compliance with relevant regulations and internal policies/standards as they pertain to CIB Client Coverage and Transaction Services.
• Collaborate with training teams, where requested or deemed necessary, to input into training curriculum to support closing of capability gaps and to meet the training needs of CIB Client Coverage, Transaction Services & Functions.

Risk Management

• Support efforts to anticipate horizon risks that may have a significant impact on the Bank and develop effective strategies to mitigate such horizon risks including global standards for conduct of business.
• Support efforts to ensure the effective management of CFCR matters, management of regulatory issues that have a significant impact on the Bank and support relevant stakeholders to respond to regulatory questions.
• In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure appropriate and timely escalation within the Group and that actions are taken quickly to remediate and/or activities are ceased . click apply for full job details