Leads the GBM AML/ATF and sanctions oversight function of cash management and payment products ensuring business strategies, plans and initiatives are executed and delivered in compliance with governing AML/ATF and Sanctions regulations, internal policies and procedures. The Senior Manager is responsible to deliver effective challenge by the 2nd line of defense for the Cash Management and Payment products.
The role has expert knowledge of AML/ATF and sanctions risk profile of Cash Management and Payments products and helps the business line understand and manage AML risks across clients, products and geographies.
- Guides the business line in development of first line of defence AML/ATF and Sanctions controls
- Oversees the implementation of the business line jurisdictional AML/ATF Policies and Program reflecting the enterprise wide AML/ATF Standards.
- Acts as key GBM AML liaison on cash management and payment initiatives
- Provides oversight and coordination to 1A and 1B AML Advisor activities in the global cash management and payment business units
- Leads the enhancement of Enterprise and GBM policy as it relates to cash management and payments
- Provides AML/ATF advisory support to the business unit in matters involving client risk, client exits and approving automatic high risk clients.
- Taking appropriate and timely action in communicating and developing or amending existing policies, procedures, practices, training, and other controls in response to changing regulatory requirements and expectations;
- Identifies unacceptable AML/ATF risk, collaborating with AML Advisor and proactively managing and escalating these situations.
- Reviews and approves new initiative risk assessments (NIRAs) related to cash management and payment products and ensures controls are adequate to support initiative.
- Provides input to the business line self-assessment of inherent risk and challenges the Business’ assessment of control effectiveness;
- Provides cash management and payments subject matter expertise to global GBM AML, GBM jurisdictions Enterprise Program Office, FIU and Audit.
- Develops plans to remediate issues raised by Audits, 2nd line Testing and regulatory examinations and monitors and reports on the status of the remediation plans.
- Monitors the schedule and results of the AML Advisor’s quality assurance of the businesses to identify potential weaknesses and trends.
- Reviews and provides credible challenge on AML and sanctions metrics for cash management, payments and MTO with an aim to identify emerging risks, issues and trends
- Develops training plans for business units and assists in the development and/or presentation of the training as appropriate.
- Understands how the Bank’s risk appetite and risk culture should be considered in day-to-day activities and decisions.
- Builds a high performance environment and implements a people strategy that attracts, retains, develops and motivates their team by fostering an inclusive work environment; communicating vision/values/business strategy and managing succession and development planning for the team.
Education / Experience
- Expert knowledge of Global Banking and Markets and Global Transaction Banking business unit functions, procedures, cash management and payment products, policies and how the various supporting units interact;
- Thorough written and verbal skills required to prepare communications and interact effectively with other Bank departments and external parties;
- Minimum of 5-7 years in financial services operations and AML/ATF compliance;
- Minimum Bachelor’s degree in business, related field or equivalent experience;
- ACAMS certified preferred;
- Strong managerial, communications, analytical, organizational, project management, and planning skills;
- Thorough knowledge of related regulatory requirements including KYC, AML, Anti-Terrorist Financing Policies, Compliance Control & Operational Risk Self-Assessments legislation and procedures;
- Expert knowledge of AML/ATF regulatory requirements and expectations.
Requisition ID: 23043