JOB PURPOSE
The job holder will be responsible for performing AML/CFT/CPF compliance function. Such functions include implementing the Bank’s AML/CFT/CPF compliance program, conducting investigations, analysis, reporting and responding to Money Laundering/ Terrorism/Proliferation Financing (ML/TF/PF) cases, identifying points of compromise and potential loss.
KEY RESPONSIBILITIES
Transaction Monitoring and Reviews
Collaborative Partnerships
Strengthening Risk Management
Reporting
Risk & Compliance
MAIN ACTIVITIES
Transaction Monitoring and Reviews
Implement adequate AML,CTF and CPF controls to ensure that all possible areas of AML, CFT & CPF concerns are covered.
Perform regular reviews of all AML, CFT & CPF controls to assess effectiveness. This includes;
Sanction and Politically Exposed Person (PEP) screening program
Transaction monitoring program
Customer and Enhanced Due Diligence program
Suspicious Activity/Transaction Reporting (SAR/STR) management program
Adverse Media mentions review program
Investigative orders management program
Perform detailed analyses to detect patterns, trends, anomalies and schemes in transactions and relationships across bank’s processes/ customers/ products.
Collaborative Partnerships
Assist in implementing a bank-wide AML/CFT/CPF program through risk awareness training program for all staff especially on identification and reporting of suspicious transactions.
Maintain detailed knowledge of current AML/CFT/CPF regulations and keep track of developments within the AML/CFT/CPF scope, sanctions, terrorist financing issues, including policies, procedures, regulations, industry best practice, criminal typologies and developing trends.
Maintain strong working relationship with internal stakeholders to ensure that compliance issues are regularly discussed and addressed.
Strengthening Risk Management
Ensure that AML/CFT/CPF procedures and processes are in line with regulatory requirements.
Proactively identify gaps in the assigned reviews, assessments, projects and follow up on implementation of agreed mitigation controls.
Monitor and track closure of management actions from the compliance reviews, regulators’ and External auditors’ reports.
Reporting
Prepare regular reports on the state of AML/CFT/CPF program to the MLRO.
Report control weaknesses or lapses to the manager in a timely manner, recommend mitigation controls or process and policy changes and follow up implementation of agreed actions.
Execution of instructions and any other duties from the Manager Compliance/ Senior Manager Compliance, as assigned from time to time.
Co – operate fully with regulators and law enforcement agents and make available required documents and information.
Risk & Compliance
Attend training and maintain knowledge of and comply with all bank policies and procedures including Anti Money Laundering/Countering Financing of Terrorism/Countering Proliferation Financing laws, rules and regulations.
Participate or undertake Anti Money Laundering/Countering Financing of Terrorism/Countering Proliferation Financing bank programs on a regular basis e.g. taking attestations, self-assessment tests, filling in compliance questionnaires as required
Comply and not to knowingly participate or assist in any violation of Anti Money Laundering/Countering Financing of Terrorism/Countering Proliferation Financing laws, rules, regulations or internal policies, procedure and guidelines.
Report suspected money laundering cases to their respective heads of units or to the Money Laundering Reporting Officer as soon as such incidents occur immediately with a clear basis of suspicion
Avoid Misrepresentation and Malicious Reporting – knowingly making a false, fictitious or fraudulent representation e.g. statement, report, document.
Avoid Tipping Off customers being investigated so as not to knowingly prejudice an investigation by disclosing information.
Not provide advice or other assistance to individuals who attempt to violate or avoid Anti Money Laundering/Countering Financing of Terrorism/Countering Proliferation Financing laws, rules, regulations or corporate policies.
Co – operate fully with regulators and law enforcement agents and make available required documents and information.
DECISION-MAKING AUTHORITY
Closure and escalation of alerts
Suspicious transaction to be reported
Appropriate documentation for use in Suspicious Activity or Transaction supporting documents
Transactions to be marked in the system as suspicious
Customers to be updated in the blacklist
Communications to business on awareness on issues and trends noted
Appropriate remediation action on implementing the banks AML/CFT/CPF program
Training requirements for the business
Compliance activities to be monitored
High-risk accounts to be reviewed
ACADEMIC BACKGROUND
Bachelor’s Degree in Business related course or equivalent.
Anti-Money Laundering Certification
WORK EXPERIENCE
At least 4 years’ banking experience in AML/CFT/CPF in an Enterprise Risk Management function.
SKILLS & COMPETENCIES
Knowledge of money laundering techniques and regulations
Knowledge of regulatory compliance requirements and risk management principles
Demonstrable analytical skills and Experience in working with Server Query Language (SQL) and analyzing large volumes of data
Good knowledge of payment services and operations
Good Organizing and planning skills
Good knowledge of payment services and operations
Results oriented, effective communicator and a team player eager to learn and share experiences
Proficiency in Microsoft Office Applications
PROFESSIONAL CERTIFICATION
Certification in a professional association such as the Association of Certified Anti-Money Laundering Specialists (ACAMS)
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