Overall Job Purpose
To ensure compliance by business with its obligations in terms of the Anti-Money Laundering (AML) and terrorist financing legislation/regulation and its employees with the provisions of the applicable laws and internal policies and rules.
To ensure adherence by BUSINESS with the Sanctions and Anti-Bribery and Corruption (ABC) Policy requirements
To provide AML related training to the business.
Accountability: Implementation, embedment and oversight of AML, Sanctions and ABC
Provide guidance/support to the Anti-Money Laundering (AML), ABC and Sanctions
functions within Business Units (BU) to ensure:
Full financial crime regulatory compliance
The awareness of processes to report suspicious transaction reports
There is a framework for managing the process for the escalation of
dispensations / waivers to the Head of Financial Crime on behalf of a BU
Assist the relevant BUs in the interpretation of policies and standards as required.
Monitor, by checking, that relevant BUs provide awareness and training programmes in respect of Money Laundering, Sanctions and Bribery & Corruption in accordance with the statutory requirements and report on completion of training
Guide relevant BUs with regard to compliance with any AML; ABC or Sanctions related issues arising from regulation or policy
Guide relevant BUs with regard to the remediation required following any form of assurance review conducted (i.e. Internal Audit, Financial Crime)
Participate with business when new products are being developed to ensure financial crime compliance.
Provide Financial Crime input into the Africa NPA process
Obtain and review of monthly financial crime reports from designated in country team members
To design and implement ad hoc financial crime training to relevant BUs in line with the Barclays Policy requirements
Accountability: Annual High Risk Reviews:
Ensure the relevant BUs understand the standard required to be performed, including the record retention requirements for Annual High Risk Reviews.
Provide training to users on the standard compiled
Track progress and completion of Annual High Risk Reviews
Conduct reviews on the High Risk Reviews that have been performed
Ensure the maintenance of the High Risk database and provide reports as and when these are required.
Escalate to the Manager: Financial Crime BUSINESS, any missed deadlines in this regard
Accountability: Politically Exposed Persons:
Ensure PEP register is complete and maintained by relevant BUs.
Provide advice on the PEP review standard to be used.
Assist in providing training to users on the standard compiled.
Conduct reviews on the PEP Reviews that have been performed.
Accountability: Financial Crime Reporting:
Test that relevant BUs maintains records relating to Dispensations, Waivers, Exceptions and Breaches log.
Compile the monthly KRI reports relating to business
Provide relevant, accurate and updated information on request or in terms of agreed time lines to be included in various stakeholder reports such as CRC, Combined Assurance, Exco.
Accountability: Stakeholder management:
Build and maintain meaningful relationships the BUSINESS BUs with the aim of 3 understanding their business needs.
Ensure that updates/review/testing reports are discussed and submitted timeously to the relevant COO.
Apply consistent Financial Crime standards across BUSINESS
Accountability: Policies and Procedures:
Facilitate and embed policies, processes and business requirements to ensure that risk is sufficiently mitigated in BUSINESS.
Act as point of reference for regulatory queries and breach, dispensation and waiver requests.
