Senior Manager Cmb Monitoring And Testing And Fcc Risk Response

Job description

Role Title: Senior Manager CMB Monitoring and Testing and FCC Risk Response
Business: Financial Crime Compliance
New or Existing Role? New
 
Role Purpose


HSBC’s FCC Monitoring and Testing programme (FCC M&T) provides ongoing, periodic monitoring and comprehensive testing for Financial Crime Compliance requirements.  The bank’s Monitoring and Testing model will operate consistently in all countries to deliver greater transparency and consistency in the reporting of global FCC risks.

In their CMB Monitoring and Testing capacity, the role holder will be a vital link globally between the Global Heads of; CMB FCC; Global Heads of FCC; AML / Sanctions / ABC / M&T and be responsible for global oversight of the implementation of Compliance Monitoring and Testing (CMAT) strategy across CMB in order to obtain reasonable assurance that the business is managing its financial crime risks and operating in line with relevant laws, regulations, codes and HSBC Group Standards.

In their risk response capacity, the role holder will be called on to provide ad-hoc reviews on high profile emerging risks requiring an urgent risk assessment for Senior Management. The review activity can be across multiple jurisdictions and business lines and covers all FCC disciplines and the role holder will provide assessments and recommendations for immediate action by management in region and country. The role holder will frequently act in a senior capacity giving direction to country or regional resources for the duration of the ad-hoc review. 
 
Key Accountabilities


Participation in the end to end risk assessment process and application of high level specialist knowledge or global business knowledge to agree the scope of targeted reviews against emerging risks and / or high priority risks as requested by Global FCC and CMB Business Management.

Working closely with the FCC Risk Assessment Teams and Regional FCC M&T Teams to agree an appropriate M&T Plan that addresses the global priority risks.

Utilising high level senior SME knowledge in the FCC M&T risk environment by providing rapid "hands on" risk response to significant emerging risks to identify root cause, potential impact and advise on next steps;

To be strategic, internationally mobile and manage a team of internationally mobile specialists to conduct thematic first line reviews where local FCC M&T resource is unavailable

Identify and make decisions on how to implement changes that mitigate risks that may result in the first and second lines of defence performing their role more effectively;

To conduct controls effectiveness testing; and

Provide a flexible service that can be relied upon to deliver results, often under pressure, in a very timely manner and frequently within short timescales.
 
 
Impact on the Business/Function


To provide CMB input into CMAT strategy development and subject matter expertise on global annual Business Plans to CMAT Global Heads

To provide CMB input into the Risk Assessment process to ensure the global priority risks are correctly identified for CMB.

To identify and escalate trends, issues and risks identified through CMB CMAT activities globally to CMB FCC Management

Escalate country-level compliance risks that may have implications on other HSBC Businesses and Functions globally

The Global Risk Response team will be called upon to support Regional M&T teams in delivery of their risk based annual plans by working alongside local resource to deliver “high risk” reviews, which are at risk due to resource/local priority constraints

The Global Risk Response team will be called upon to support review activities of high urgency and high priority as identified by Global FCC or Business Management to inform and advise immediate and near term risk mitigation strategies to address FCC risks that are outside of risk appetite or tolerance

The jobholder will provide innovative and effective solutions based on their SME knowledge that assist the Business/ Function
 
 
Customers / Stakeholders


To engage with the Global and Regional Risk Assessment Teams to ensure CMB/Functional risk assessments are carried out effectively and the global priority risks are correctly identified for CMB.

To engage with Regional Heads of CMAT and Global Head of CMB FCC/RC on emerging global themes and compliance risks that could impact the Global CMB business.

Collaborate with Global Business and Functional Heads (external to Global Compliance) on any relevant CMAT key findings or open issues.

Collaborate with AML, Sanctions, Anti-Bribery & Corruption policy owners on horizon risks that may impact the Global CMB Business.

Maintain an open channel of communication with external Regulators in order to direct and respond to Regulatory enquires.

Interact with and coordinate activity with the respective Functional and Regional heads of M&T.

Ensure progress on reviews and findings are captured into the management
 
Leadership & Teamwork


Have a voice globally and be there to provide guidance and CMAT advice to FCC CMB

Build relationships with senior FCC/RC decision makers and advise on any  Line of Business challenges

Develop new and efficient ways to assist the Business line and associated Business Risk Control Management (BRCM) teams in first line control management   

Actively engage with Compliance Senior Management to ensure delivery of compliance management and performance information.

Coordinate activity with Functional and Regional M&T heads to avoid duplication and optimize efficiency / effectiveness.

Take a lead role in creating awareness of the CMAT methodology
 
 
Operational Effectiveness & Control


The jobholder will continuously assess the compliance testing framework (together with functional M&T heads) by developing and implementing innovative approaches to compliance testing and review.  Identify and implement efficiencies to ensure maximization of Compliance resources.

Together with functional M&T heads the jobholder will lead the development and evolution of Compliance Monitoring and Testing systems, tools, and training.

The jobholder will implement the Group compliance policy locally (together with functional / regional M&T heads) by managing compliance risk in liaison with the Global Head of Compliance, Global Compliance Officer, Area Compliance Officer or Local Compliance Officer, ensuring adequate compliance resources and training.
 
 
Major Challenges


Financial Crime Compliance is going through a period of rapid and deep change with the restructuring of the Group’s footprint and ensuring that these businesses are run consistently and globally.

Balancing the FCC requirements in line with the risk associated with the issues identified or arising.

Keeping abreast of changes to the regulatory environment and being alert and agile to ensure these are reflected in CMB plans.
 
Role Context


HSBC's Second Line of Defence Financial Crime and Regulatory Compliance Monitoring & Testing programme provides comprehensive risk-based monitoring and testing related to the effectiveness and adequacy of the Financial Crime and Regulatory Compliance risk and control activities conducted by the first line.

This is a Second-Line of Defence global role in which the job holder is required to lead a global team to facilitate the oversight and prioritisation of CMB CMAT requests globally.

The individual must provide a rapid "hands on" risk response to significant emerging risks to identify root cause, potential impact and advise on next steps.

The individual must be internationally mobile to conduct thematic first line reviews where local FCC M&T resource is unavailable or stretched too thinly to respond appropriately (in which case a collaborative approach is to be adopted). 
 
 
Management of Risk


Awareness of global Regulatory, Business Conduct, and Financial Crime Compliance risks associated with the Global business lines.

Monitor in accordance with the Principle Accountabilities set out above

The jobholder will also continually reassess the operational risks associated with the role and inherent in the business, taking account of changing economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new technology.

Assist Senior Management in identifying and managing compliance risk, monitoring, reporting and certification, and fostering a compliance culture
 
Observation of Internal Controls


Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.

Assists in the discharge of accountabilities set out in the Legal & Compliance FIM by proactively assisting the monitoring teams in their responsibilities to assist management in identifying and mitigating compliance risk, monitoring, reporting, fostering a compliance culture and optimising relations with regulators.

Desired profile

Knowledge & Experience / Qualifications


Proven senior management experience in financial services operations, compliance, audit and/or legal management experience or equivalent.

Minimum Bachelor’s degree in related field such as business, finance, law or equivalent experience; Master’s degree preferred.

Requires expertise in compliance and risk controls and must be conversant regarding relevant regional laws, regulations and the overall regulatory environment. In depth understanding of the key risks and controls applicable to each of the compliance functional areas (AML, ABC, Sanctions)

Requires in-depth and innovated insight of the understanding of the changing regulatory landscape surrounding Compliance organisations within the banking industry.

Broad and in-depth  scope of knowledge of businesses, including products, operations, systems and organization

Demonstrated experience as an effective overall leader with excellent communication skills, a polished management style, and a proven track record of leading through change.

Demonstrated experience and confidence in working with a global team and creating and working to a high global standard of quality.

Proven ability to question, evaluate, improve and innovate existing business processes and adequacy of information.
 
 
Within HSBC certain roles are designated as Enhanced Vetting Roles. For these roles, all internal and external applicants are required (subject to local laws), to pass satisfactorily a series of additional checks both as part of the application process and, if successfully recruited into the Enhanced Vetting role, on an on going basis. The Group reserves its position with regard to any steps which it may take in relation to any material adverse findings which arise either when the checks are first carried out as part of this recruitment exercise, and/or if relevant, on an ongoing basis.
This role has been designated as an Enhanced Vetting Role.
For more information about the relevant additional checks for this role please contact the hiring manager

About HSBC

HSBC est l’une des plus grandes banques internationales avec une présence dans plus de 85 pays dans le monde. Elle a été créée en 1865 sous le nom de « The Hongkong and Shanghai Banking Corporation », et son siège social est basé à Londres. En France, HSBC totalise environ 400 agences et près de 10 000 salariés, avec une spécialisation dans plusieurs activités : une banque pour les particuliers, spécialisées notamment dans la gestion de patrimoine, une banque privée (gestion de fortune), une banque d’entreprises, qui s’appuie sur le réseau de l’ensemble du groupe HSBC dans le monde, et une banque de financement, d’investissement et de marchés. En 2012, HSBC France a réalisé un résultat avant impôt de 450 millions d’euros.