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Summary The Senior Manager has responsibility for the establishment and maintenance of effective Anti-Money Laundering systems and controls under SYSC 3.2.6HR.
The role also has functional responsibility for all other AML roles in other entities such as SG Hambros. The financial crime remit covers anti-money laundering, terrorist financing, bribery and corruption and the reporting of suspicious transactions in respect of fraud and market abuse for regulatory purposes and to SOCA for anti-money laundering purposes. Note that the responsibility for managing fraud as an operational risk lies externally to Compliance but the reporting responsibility is managed by the Head of the Financial Crime Unit. The business carried on within SGLB is primarily Corporate and Investment Banking (CIB), including capital markets, capital raising, lending, advisory, commodities and principle investing. Various other non-CIB activities such as clearing and settlement on behalf of correspondents and Cash Management are carried on through SGLB as well. Main responsibilities The role is very broad and encompasses a wide variety of tasks and responsibilities. Duties will include but the following will not be exhaustive: • Managing the Financial Crime team of two reports giving direction in the handling of financial crime risks and issues and in the management of financial crime incidents; • Ensuring that AML and KYC policies comply with UK requirements within SGLB and liaising with SGUK AML functions to ensure consistency. In addition, to liaise with the SG Group Compliance function in Paris in respect of these policies; • Developing, implementing and managing the anti-financial crime strategy within the UK covering anti-money laundering, terrorist financing, bribery and corruption. To liaise with SG Group Compliance in Paris in respect of that strategy; • Advising local and Group management on complex financial crime issues; • Providing advice, direction and training to the KYC function and approving high risk accounts referred by the KYC team to the financial crime function; • Developing and maintaining appropriate monitoring and controls of the KYC function; • Maintaining and continuing to develop the risk assessment processes including the country risk assessment process; • Overseeing and, where appropriate, undertaking, the internal investigation of financial crimes including money laundering, criminal and terrorist activities or irregularities, and market abuse as well as other regulatory enquiries and submitting reports to SOCA and FSA; • Developing, implementing and overseeing financial crime review programmes, including the monitoring and surveillance of AML within SGLB, ensuring timely identification of risks and the development of cost- effective and efficient counter-measures. • Influencing the approval of new products from a financial crime perspective; • Implementing and maintaining appropriate management information for financial crime; • Advising on the planning, review and design of sanction/embargoes controls; • Developing and overseeing financial crime training. • Ensuring appropriate links are made with the AML functions in non-SGLB functions and appropriate monthly reports are obtained and reviewed. • Currently two senior AML officers report into this position. Level of authority • The Head of Financial Crime and MLRO is responsible for managing this function and providing appropriate reporting to the Head of SGUK Group Compliance, the Chief Country Officer (CCO) and to the SG Group Compliance function. Internal & external contacts • Frequent interaction with all levels of staff, particularly with business managers and the CCO. • Responsible for liaising with FSA, SOCA and other external counterparts; • To maintain appropriate relationships with AML and financial crime associations
CANDIDATE PROFILE Education • Degree Educated • Post-degree AML and Financial Crime qualifications Past experience • MLRO/ head of Financial Crime or Deputy MLRO/Financial Crime in a large firm with similar businesses to SG with significant experience Languages • Fluent English • French would be an advantage but is not a requirement Competencies Required Management Skills Operational Skills Regulatory Skills Communication Skills Flexibility - Adaptability Ability to make Decisions Ability to Work Under Pressure Analytical Skills Initiative Leadership Qualities Teamwork Personal abilities • Applicants will need a broad and detailed knowledge of all aspects of financial crime in respect of financial services, particularly investment banking. They will be expected to have a good working knowledge and understanding of the UK financial crime regulatory and statutory framework and legislation and also the EU AML regulatory and statutory framework; • Able to keep abreast of market standards and practices; • Applicants will need a broad knowledge of investment banking products and business activities; • The ability to communicate effectively and to influence senior managers and external parties ; • Able to apply the AML provisions in a fast paced and diverse business environment.
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