Global AML and Quality Management Associate
Royal Bank of Scotland
Total years of experience :25 years, 9 Months
Responsible for the definition and implementation of quality process mapping, procedure writing, financial crime investigations skills ensure complete coverage of required client risk assessment. Assist existing policies updating and streamlining across the global business lines. Part of annual Risk Assessment questionnaire based where stakeholders has to provide rationale and score/rating them along with evidence to support their response. Assessing (QA) completed by both KPMG and RBS staff. Analysis and support the CDD team in providing guidance to the business on all aspects of financial crime, sanctions, bribery, especially fraud and anti-money laundering to achieve business objectives. This will include all global CDD assurance over financial crime and systems and key controls. Also validation reviews, including validation of fraud, PEP and sanctions screening systems.
. Duties Included:
• Part of Risk Assessment 2015 and 2016.
• Monitoring financial crime exposure across the Group in order to plan and conduct proactive reviews through the collection and analysis of intelligence and produce reports that provide assurance, meet regulatory expectations and support business areas in implementing solutions and controls which act as a deterrent
• Identify, secure and evaluate intelligence sources relevant to financial crime investigations in order to assist in the validation of allegations of fraud and provide relevant information to investigators in order to mitigate the risk of reputational damage and/or financial loss
• Help drive the documentation of detailed fraud risk vulnerabilities, threats, controls, and scenarios including analysis, presentations, coordination and communication, and project management/coordination during the entire Fraud Risk Assessment process.
• Testing application and effectiveness of financial security policies and procedures (by undertaking AML assurance testing as defined in the control and monitoring procedures) across CIB business areas and functions.
• Assist in the development and implementation of policies relating to Anti-Money Laundering (AML), Counter Terrorist Financing (CTF) and Sanctions.
• Assist in the implementation of the Target Operating Model for the CDD operation.
• Support analysts on-boarding/Off-boarding, Exiting clients, Ring-Fencing strategies.
• Execute quality assurance reviews using pre-defined sampling methodology.
• Investigate, escalate and record alerts raised as a result of financial crime screening.
• Provide support to US, EMEA and APAC teams regarding AML/Sanctions and KYC quality assurance issues.
• Strong working relationships with Audit, Compliance and Operational Risk and across the lines of business. Liaise with these departments as appropriate to ensure timely identification and resolution of Financial Crime related issues.
• Ensure systems, processes and controls are adequate to prevent, detect and deter financial crime, and work to resolve where there are gaps/deficiencies.
• Monitoring Client on boarding / off boarding.
• Evaluate the findings and recommend/provide feedback for improvement.
• Monitor the implementation of accepted recommendations.
• Identify issues with the purpose of optimising and synchronising policies and procedures
• Identify and escalate potential risks and operational issues as appropriate
• Co-ordinate quality improvements review with other QA groups, Compliance, Audit.
• Ensure consistency in reporting of quality issues and quality improvement results, participating in the QA Panel on monthly basis.
• Prepare and execute training based on results trending analysis.
• Review 2016 Periodic Review cases that need business inputs.
• Initial review of AML checklists, track changes and coordinate completion of annual reviews.
Prepare and review key documents covering scoping, process understanding, risk & control identification, control evaluation and observation/report. Manage the assurance review to ensure that relevant data feeds, risks and controls have been identified, appropriate test strategies have been adopted in line with the method and the compliance of processes and the screening tool in meeting relevant policy requirements. Lead discussions with the Lloyds Group Compliance Assurance team members regarding observations arising from the assurance reviews. Support Compliance management in identifying resolutions for control issues identified and /or non-compliance to policy, to address root causes. Correctly identifying, verifying, screening and recording Key Principals and Beneficial Owners - Capturing adequate proof of existence of entities under review, Ensuring that the appropriate Risk ranking (using CRA tool) is correct and captured in the data hub, Identifying and reporting any unusual entity structures, identify anomalies or any activities that arouse suspicion that a customer is engaged in Money Laundering or Terrorism activity, Maintaining accurate statistics about case volumes worked.
• Completed extensive formal training to enable full understanding of role requirements.
• AML risk analysis: Trusts, SVPs, Correspondent Banking, High net-worth individuals, Charities, Event Triggers etc.
• Provided technical KYC/AML policy and procedural support to assist client on-boarding.
• Managed KYC and OKYC documentation in accordance with Company and Regulatory requirements.
• Reviewed financial and other documentation as part of an AML banking fraud investigation.
• Analysed information from internal and external sources including Corporate Intelligence team.
• Investigated activities of clients to determine integrity prior to issue of AML Certificate.
• Supported client due diligence for International entities in a wide range of sectors.
• Undertake independent regular targeted, risk based sampling reviews of KYC assessed and completed cases in line with Group Wide Policies and Customer Due Diligence Standards.
• Confirm that KYC Analysts and Quality Control analysts have made the correct decision looking for a regulator ready rationale to support the decision.
• Ensure there is clear and complete audit trail of documentary evidence to support the decision and a clear rationale is attached to files.
• Identify and report on fails (and their root causes) in accordance with the standards in the assessed and completed KYC cases.
• Feedback findings on gaps to KYC analysts and Quality Control analysts to embed improvements, reducing errors and supporting risk mitigation.
• Produce Management Information to identify common themes.
• Support the interaction with other key stakeholders in the integrated assurance framework.
• Support the KYC QM in the continuous improvement of systems, processes and procedures.
• Contribute to the ongoing improvements of CDD Quality Assurance.
I work closely with MLRO. Participated in AML/KYC projects to enhance existing client risk ratings and analysis systems. I involved remediation process and procedures to comply FCA section 166 findings also coordinated with I.T to enhanced existing monitoring system. Duties included:
• Initiating any remedial action required as a result of the monitoring and ensures that the remedial action is completed within a reasonable time frame.
• Select and maintain Automatic transaction monitoring system.
• Timely follow-up on recommendations agreed with the relevant stakeholders on the back of level 2 controls or monitoring reviews findings.
• Evaluate monthly database and noted any account activities that required further investigation.
• Preparation of SARs for external disclosure.
• Recognising and reporting suspicious activity & transactions
• Compiling breaches/incident reports arising from monitoring activity investigate issues arising and report the outcome.
• Assisting in any process review to ensure the monitoring programmes continue to test all appropriate areas of risk.
• Review and test the AML policies, procedures and internal monitoring practices
• Facilitate AML audits (Internal and external)
• Identifying, investigating, reporting and escalating errors and breaches.
• Performed follow-up investigations.
• Works with AML Unit Management to develop and execute a complete quality control and assurance program for all AML related activities. Assisted process review to ensure the monitoring programmes continue to test all appropriate areas of risk.
• Conduct staff quarterly AML training.
• Confirmed compliance with Fraud protection guidelines.
• Assist "exit client" Project
Responsibility includes to working closely with decision makers in other departments to identify, recommend, develop, implement, and support cost-effective technology solutions for all aspects of the organization, as well as an interface with Corporate Management and business partners and also define and implement IT policies, procedures, and best practices. Manage the deployment, monitoring, maintenance, development, upgrade, and support of all Infrastructure systems, including servers, operating systems, hardware, software, storage area networks and backup systems.
o Managed 20-location wide area network.
o Training and supervising staff.
o Organizing strategic activities to attain goals and objectives.
o Configuration and Maintenance of Network based on Cisco Routers, Ethernet Switches and Windows NT / 2000 servers running MS Exchange, MS Proxy, IIS and MS ISA Server.
o Creation and enforcement of network security policies and procedures.
o Implementing and maintaining real time monitoring of circuit, router, and server health.
o Interfacing with telecom providers for ordering, provisioning, and troubleshooting of services.
o Managing equipment inventories and software licensing.
MHA is the definitive financial crime resource with the expertise to provide effective and compliant financial crime risk support. Achieved vital information and specialist knowledge in all areas including anti-money laundering, sanctions, compliance, fraud and bribery & corruption.
Bribery and Corruption – what systems, controls and procedures you should have in place to deal with the UK Bribery Act. Recent AML and Financial Crime Enforcement Actions against Firms/Individuals. FCA’s Thematic Review of High Risk AML Issues: PEPs, Correspondent Banking and Wire Transfers. Provide intensive training and provide delegates with the opportunity to upgrade their skills and knowledge. Provide a forum for MLRO professionals and senior executives to network with each other and to share knowledge and experience. (Organised and Certified by The COMPLIANCE REGISTER)
1st Division.
