Head of Financial Crime Risk

6 days ago

London Area, United Kingdom BACB plc Full time

About Us

BACB is a UK bank that offers trade finance and investment expertise to clients in specialist markets, especially Africa and the Middle East


We have been helping businesses with trade finance and complementary products for over half a century, focusing on trade flows to and from Africa and the Middle East as well as real estate in the UK.


Our in-depth knowledge of the countries and practices where our clients operate ensures that we put them first.


Additional Info

  • Hybrid Working: 3 days onsite, 2 from home
  • Location: City of London
  • Contract Type: Permanent


The Role

Reporting directly to the Chief Compliance Officer and MLRO (CCO), you'll lead the 2nd LoD Financial Crime Risk (FCR) management function on a day to day basis.


The FCR comprises circa 8 FTE and is organised across 3 different workstreams;

  • Financial Crime Advisory – provision of on-demand financial crime SME knowledge to all areas of the Bank
  • Core Services – policy, framework and risk assessment. Also provides core KRI metrics dashboard and systems oversight.
  • Financial Crime Monitoring and Testing – independent 2nd line assurance reviews and business-wide risk assessments


SMF17 responsibility is assigned to the Chief Compliance Officer and MLRO, but some of those responsibilities will be delegated to the Head of Financial Crime Risk.


Role Responsibilities

  • Develops and implements a FCR risk management framework that is line with the Bank’s risk appetite, including establishing appropriate FCR appetite and tolerance, key risk and performance indicators and early warning signals.
  • Leads and manages a team of FCR specialists ensuring that the function is suitably resourced to meet its goals.
  • Assesses adequacy and effectiveness of FCR systems and controls Bank wide including resources and conduct/culture.
  • Oversees and develops FCR policies, procedures and reporting in the second line of defence and act as the FCR ‘standards setter’ for the first line of defence.
  • Works with the CCO to prepare, manage and monitor annual FCR framework ad programme with consideration of existing and emerging FCR risks in line with FCR risk appetite, resourcing and technology enhancements (where appropriate)
  • Manages the Bank’s FCR Monitoring and Testing Programme.
  • Key stakeholder in the standards, capability and performance of the 1st line of defence Client Due Diligence and Financial Crime Operations Teams.
  • Develops in conjunction with first line of defence a sustainable compliance programme for AML, KYC on-boarding and periodic reviews of the Bank’s clients.
  • Manages, maintains and develops relationships with internal departments, clients and counterparties, and other stakeholders such as regulators and auditors, including rep offices and clients’ financial crime departments in overseas jurisdictions.
  • Provides training and support as required in the Bank’s FCR risk management frameworks, in particular AML, KYC, FCR ABC & Sanctions.
  • Assessment and action of FCR legal and regulatory obligations, regulatory change monitoring and management, horizon scanning over following 12 months of FCR regulatory changes.
  • In conjunction with the CCO prepares and submits Annual MLRO, FINCRIM report and all FCR regulatory submissions.
  • Ensures accurate, timely and sustainable metrics are provided to the CCO for onward reporting.
  • Oversees the preparation of the firm’s annual business wide financial crime risk assessment.
  • Escalation of matters to the CCO where required.
  • Attraction, retention and development of a motivated team of financial crime specialists within the Bank.


Experience Required

  • Prior experience working as Deputy MLRO or Head of Financial Crime
  • Deep understanding of the technical aspects of International Sanctions, AML regulation, ABC regulation and Fraud
  • Experience of dealing with high-risk products, customers and jurisdictions
  • Extensive contact/experience of dealing with OFSI, FCA and/or PRA on financial crime matters.
  • Extensive Financial Crime risk management experience gained in the financial services industry.
  • Trade Finance, Commodity Finance and Correspondent Banking product experience preferable.
  • Educated to degree level and/or relevant professional qualification.
  • Previous experience of working in a UK subsidiary of a non-EU parent company

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