Job Purpose:

To develop, strengthen and maintain a Sanctions Compliance and Know Your Customer (KYC) / Onboarding program for the bank. To manage real-time monitoring of inward and outward remittances against local and international sanctions requirements, CBI Compliance requirements and international best practice.

To investigate any blocked transactions and any other potential sanctions concerns. To remain at the forefront of regulatory developments and international best practice on risk typologies, trends and methodologies around KYC and Customer Due Diligence (CDD) standards and requirements.

To pro-actively manage correspondent banking compliance relationships, with emphasis on thoroughly understanding and management of our key correspondent banking relationships, in liaison with our stakeholders at Financial Institutions.

To ensure that Senior Management of the bank are aware of the risks and resultant actions to be taken. To manage a team responsible for conducting enhanced due diligence reviews to support informed, risk-based decision making in the best interests of the bank, in line with the bank's risk appetite, regulatory requirements and correspondent bank expectations.

Being the subject matter expert and cohesive partner to stakeholders with primary advisory responsibility on Sanctions, KYC and CDD standards to be applied and followed across all areas and products of the bank.

Undertaking all overarching monitoring responsibilities associated with the area of specialization to provide informed and dynamic management information to support the ongoing assessment of a risk-based approach, in line with the bank's risk appetite.

Reports directly to:

VP Head of FCC - MLRO

Duties and Responsibilities:

Sanctions Monitoring and Reviews

Assisting in developing a sanctions compliance program for the bank under the supervision of the Senior Manager Financial Crime Compliance
Managing the investigation of payment sanctions screening alerts and ensuring the necessary actions are taken.
Providing guidance and advice to customers and Payments Sanctions Screening (PSS) Officers / Sr. Officers on sanctions and the alert investigation process, highlighting requirements and methodologies to follow.
Escalating any potential violation/exact match involving sanctions designated individuals /entities to the Senior Manager Financial Crime Compliance/Head of Compliance immediately.
Managing queries, follow-up with the relevant business unit and ensure all alerts are attended to within the agreed Turn Around Times.
Providing guidance and advice to Business /Operations staff in sanctions related cases.
Ensuring proper identification of typologies and red flags during sanctions screening investigations.
Being responsible for list management to ensure proper screening is undertaking to detect and avoid sanctions breaches whilst simultaneously minimizing the number of false positives, where possible.
Maintaining relevant watch lists into the sanctions screening system including prohibited countries, Good Guy Lists and internal lists.
Ensuring all correspondent bank queries and requests including specific requests on transactions as well as requests relating to the completion of correspondent bank AML/KYC/USA PATRIOT Act Certificates are properly responded to within agreed / reasonable time frame.
Performing periodical quality assurance of customers screening alerts.

b) KYC/CDD Management (customer onboarding):

Assisting in building a scalable operating model, which can provide a best in class client onboarding and ongoing CDD/ KYC Compliance experience, whilst also meeting regulatory requirements.
Leading, mentoring and managing accountability for the team to drive an optimized operating model and drive process changes and efficiency opportunities and to ensure that business deliverables are met
Have ongoing/ periodic customer due diligence reviews performed to ensure the risks associated with customers are sufficiently addressed through the frequency of reviews.
Liaise with the Regulatory Compliance Team or Centralized Controls & Governance Team to ensure that assurance exercises performed by either of these teams on onboarding cases or revision of existing customer relationships are being facilitated.
Investigating suspicions identified during ongoing/ periodic due diligence reviews to ensure adherence to regulatory customer due diligence and reporting requirements.
Managing the due diligence and risk assessment analysis in accordance with regulatory expectations regarding establishing correspondent bank relationships and vostro accounts

c) Policy Setting and Advisory

Developing, updating, implementing and maintaining policies and procedures around sanctions, customer onboarding, enhanced due diligence requirements, Know Your Customer standards and ongoing/ periodic customer due diligence reviews in line with local regulatory requirements and international best practice expectations, including the FATF recommendations.
Developing, bi-annual updating, and maintaining lists of types of prohibited accounts, high risk countries and high industry types in line with CBI compliance policy, local regulatory requirements and international best practice and ensuring staff are aware of these requirements.
ensuring awareness regarding adherence to KYC and CDD requirements, impact of applicable sanctions considerations, high risk geographies, industries, activities and typologies. Ensure that guidance, be given to staff to enhance their understanding of the requirements.
Evaluating Sanctions and AML risks, trends and typologies against the internal KYC compliance processes and controls to identify opportunities for improvement, efficiency, risk reduction and potential automation.
Continuously assessing the financial crime environment and regulatory developments to ensure anticipation of emerging risks and to implement proactive measures to enhance the sanctions, KYC, due diligence and customer risk controls based on ever-changing money laundering trends, typologies and red flags
Managing a risk-based customer risk assessment framework through dynamic risk assessment methodologies supporting local regulatory requirements, industry standards and the bank's AML risk appetite.
Being the focal point of contact engaging with senior management on complex sanction or KYC related matters and customer risk assessments to assist with informed risk-based decision making in the best interests of the bank

d) Training:

In accordance with the annual Training & Awareness Plan, establishing/ creating comprehensive Sanctions and KYC training content (including e-learnings, face-to-face or virtual, as the case may be), as well as conducting bespoke training on a needs basis to targeted audiences in addressing associated identified risks and ensuring ongoing awareness and appreciation around related compliance trends, developments and risks

e) Management Information and Reporting

- Developing and maintaining appropriate MIS (daily, monthly, quarterly, annually) of Onboarding Cases, HR relationships, Rejected Relationships, Management and Committees Approvals, Screening Alerts and Investigations and correspondent banking requests.

- Undertaking tasks as may be required by the Senior Manager Financial Crimes Compliance.

f) Systems and Technology

- Periodically reviewing, testing and tuning the available Sanctions systems, reporting results and recommendations to Head of FCC and ensuring proper follow-up with IT for any identified gaps or on any ongoing projects

- Establishing and informing comprehensive robust and strategically informative management information analysis and reports across the full KYC program.

- Advising on enhancements of the existing systems or on introducing new technologies

G) Governance:

- Sponsor and oversee risk scoring effectiveness.

- sponsor and oversee of list management (watch list, internal, whitelist, deny list) , and screening controls across onboarding, payments, and Trade Finance.

- Ensure policy and procedure completeness, identifying gaps against regulatory circulars and driving timely remediation.

- Oversee FCC data quality and record-keeping (archiving) controls to support audit and regulatory requirements.

- Proactively identify governance gaps and lead corrective actions ahead of regulatory or audit findings.

Education & Qualifications:

•Tertiary education with a Bachelor's degree as a minimum.

•Mandatory Compliance qualification or certification mainly CAMS and CGSS. CFCS certification or any other relevant AML/ Compliance qualifications from an internationally recognized body is a plus

Experience:

•Minimum 8-10 years experience in a banking / financial institution environment of which 6-7 years experience should have been in AML Investigations or similar department

Other Skills Required for the Job:

•In depth knowledge of CB UAE and other related AML / CTF regulations

•Analytical, investigative, problem solving and decision-making skills

•Attention to details

•Independent and self-starter

•Organizing skills

•Strong team player

•Good written and oral communication skills

• Good time management skills and adherence to deadlines

Senior Manager Sanctions Screening & Onboarding - Emirati Talent