Senior Manager Financial Crime Compliance, Anti-Money Laundering Policy

Job description

Employment Type: Regular
 
Support the Head of AML Policy on Policy Advisory in the overall enterprise-wide implementation of the Global AML Written Programme in HSBC Canada, with primary responsibility for supporting the creation, review and maintenance of the HBCA AML Policies and Guidance Addenda to meet local regulatory requirements, and the review of HBCA FCC procedures and Line of Business (LOB) deviations and variances to Global AML Policy
 
Impact on the Business
 
Specific areas of responsibility include:
Define and maintain the HBCA AML Policy & Guidance Addenda to the Global AML Written Programme (the Programme), incorporating applicable Canadian regulation where required;
Monitor and track AML developments, including changes to Global Risk FIM – Compliance, global AML forums, Canadian regulatory requirements and guidelines and any other relevant communication that relate to or impact the application of the Programme;
Ensure that local requirements are taken into consideration as part of the ongoing review of, and recommend enhancements to, the Programme and addenda as a result of the above and implement the changes as agreed by the Head of FCC AML/Head of AML Policy;
Support the Head of AML Policy in identifying, developing and socializing AML policy ‘definitions’ to be applied in Canada;
Provide advice, guidance and policy interpretation to the Chief Anti-Money Laundering Officer (Head of FCC) and Head of FCC AML, AML Office, FCC Operations and Line of Business Heads of FCC (LOB FCC) in relation to AML Policy & Guidance addenda and supporting procedures in dealing with day-to-day AML queries;
Maintain awareness of major AML regulatory changes affecting HBCA (enterprise-wide) and communicate changes to all stakeholders to ensure that products, services, operations and procedures remain compliant with applicable AML regulations.
Advise on key regulatory and policy changes that impact AML policy;
Work with AML Office and LOB FCC teams in reviewing and assessing gap analysis between current implementation of policies and procedures and the Programme;
Assist with review of FCC AML Function procedures and LOB deviations and variances to Global AML Policy;
Work with LOB FCC teams and FCC stakeholders to clarify and explain policy and regulatory requirements and provide recommendations to facilitate their application, and in the development and enhancement of AML controls to ensure compliance with applicable AML laws and regulations;
Work closely with the Compliance Function, LOB FCC teams and other Group Functions to promote group AML guidance and obtain their support for it;
In conjunction with the  Head of AML Policy work to discharge HBCA’s responsibility to comply with all relevant Canadian regulations, internal HSBC group compliance requirements and reputational risks and issues associated to AML matters, and by proactively assist management to identify and contain compliance and reputational risk, monitoring, reporting and certification, fostering a compliance culture and optimizing relations with regulators.
Customers / Stakeholders
Serve as liaison (as needed) to foster good working relationships with internal/external audit and regulatory agencies on an enterprise-wide basis. 
Develop external contacts among industry peer groups to determine/validate that HBCA is following and instrumental in developing industry best practice.
Leadership & Teamwork
Work together effectively to achieve functional and department goals, while encouraging individual contribution and responsibility.
Collaborate across boundaries to meet the needs of stakeholders.
Operational Effectiveness & Control
Communicate the Global AML Written Programme locally; maintain internal control standards through timely action on audit points; ensure employees are aware of compliance, internal and operational risk controls in accordance with HSBC or regulatory standards and policies; and optimize relations with regulators by addressing any issues. Emphasize and model human resources and other HSBC polices in order to create an ethical, safe and supportive work environment.
Assist investigate and report on all material and significant AML breaches/potential breaches of regulations, and support completion of corrective action where required.
Assist with preparation of AML related certification as required.
Assist in maintaining oversight over all AML Policy and regulatory and compliance matters for Canada.
Assist with the effective communication and awareness, and support queries in respect of the identification and management of applicable money laundering (ML) and terrorist financing (TF) risks.
The position works principally with the Head of AML Policy and indirectly with other FCC and general compliance staff, risk and internal control groups, and business stakeholders to support an effective enterprise-wide AML programme for HBCA.  An ability to exercise independent judgment required, with decisions beyond assigned authority referred to the Head of AML Policy for approval.
Complete other responsibilities, as assigned.
Major Challenges
Develop and maintain enterprise-wide principles for a risk based AML Program to identify and mitigate FCC AML and associated compliance risk throughout this complex business.
The position helps support FCC AML activities on an enterprise-wide basis for HSBC Canada.  Many HBCA businesses entail a high degree of FCC AML compliance and reputational risk, particularly with respect to risks arising out of non-compliance with extensive and complex regulations.  Failure to comply with these FCC AML regulations would have significant negative effects on relations with regulators, the reputation of HSBC and may result in regulatory sanctions, including regulatory fines of material amounts.
Role Context
 
Internal
FCC AML Team, Head of FCC AML, Head of FCC, Regulatory Compliance, Heads of LOB FCC, Senior Management of Businesses/Functions supported, Group Internal Audit, Legal and Group counterparts.
External
Regulators with oversight over HBCA including FINTRAC and OSFI and all other Federal and Provincial regulators.
Industry Peers and Associations – discuss best practices, trends, and common issues.
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.

Desired profile

Experienced professional with direct involvement in an AML Compliance role through a minimum of 7 years proven and progressive financial services operations, compliance or legal experience or equivalent.
Bachelor’s degree in business, related field or equivalent experience.
Proficient in local AML regulatory laws and requirements, with a full understanding of significant legislation and regulatory compliance requirements applicable to complex financial institutions and pertinent Group policies affecting their activities.
Wide scope of financial business knowledge, including products, operations, systems and organization an asset.
Excellent oral and written communication including analytical and presentation skills; organizational, project management and planning skills; negotiating and inter-personal skills and dealing with executives at all levels.
Strong technical writing skills, with ability to write concisely and deliver key messages.
Ability to respectfully communicate ideas and information (often very technical) in writing to ensure information and messages are understood and has the desired impact.
Diplomatically sensitive to understanding other people, including the ability to hear accurately and understand the concerns of others.
Proven ability to accomplish high-level objectives in the context of annual business and compliance plans.
Proficiency with personal computers and pertinent mainframe systems and software packages.