Head of AML
Commercial Bank of Kuwait
Total years of experience :17 years, 9 Months
• Acted as primary contact on AML/CTF & Sanctions risk assessment process, and collaborated with concerned departments to ensure the successful execution of AML/CTF & Sanctions risk assessment program.
• Developed a robust Risk Based Approach (RBA) and created the client risk classification matrix based on “Know Your Customer” (KYC) form; oversaw the operational implementation and technical deployment of the RBA program.
• Provided AML/CTF regulatory advisory services to ensure awareness and adherence to the AML/CTF requirements and proper identification and mitigation of regulatory risk.
• Analyzed new or amended AML/CTF regulations, domestic and international to review, develop and update policies and procedures in line with local and international best practices.
• Developed and maintained a thorough understanding of the regulatory requirements issued by the Central Bank of Kuwait, the Kuwait Financial Intelligence Unit, in addition to the international standards related to AML & CTF issued by international organizations such as FATF, Wolfsberg group and BASEL.
• Reported Suspicious Transactions (STR) with valid justifications to the Central Bank.
• Managed suspicious transaction report process including escalations to AML Committee to ensure awareness and reported to Central Bank where necessary.
• Provided guidance on follow-up actions and obtained information from the Business to ensure all enquiries from the Central Bank are responded to within the agreed timescales.
• Established and maintained the Banks Internal Black List in relation to AML/CTF to ensure that the Bank’s risk exposure is reduced.
• Reviewed and investigated all breaches discrepancies and irregular activities and recommended corrective actions to ensure risks identified are properly mitigated for the Bank.
• Managed external communications with Central Bank and correspondent banks to ensure timely responses are provided.
• Dealt with high and moderate risk alerts raised by the automated client transaction monitoring solution/system.
• Managed the testing, implementation and fine-tuning of a solution for screening client names against international and local sanctions lists.
• Implemented the identification process of Politically Exposed Persons (PEP) through the automated screening engine.
• Reviewed all products, services and delivery channels in the Bank to evaluate and advise on AML/CTF associated risks.
• Coordinated with HR and other Departments to develop effective and dedicated AML & CTF training and awareness programs.
• Setting team goals and ensuring alignment with the Bank’s objectives.
• Periodically assessed, applied and reviewed the department’s policies and procedures ensuring compliance with rules and regulations.
• Developed internal controls in collaboration with other departments to ensure compliance with Central Bank requirements.
• Developed, monitored and conducted periodic AML/CTF compliance review programs across the Bank.
• Reviewed and enhanced the existing cross-divisional workflow to maximize work efficiency through Service Level Agreements (SLA).
• Acted as contact person with regulators (Central Bank, KFIU, Specialized Committee) and external auditors.
• Direct AML team managed: 8
Responsible of ensuring the regulatory soundness of the Bank’s transactions and business dealings, performing AML/CTF reviews of business units, preparing regulatory filings, revising manuals, and addressing regulatory inquiries.
• Assist in conducting AML/CTF monitoring and regulatory investigations for reporting to the Management, the Regulators and relevant Authorities.
• Assist in establishing and maintaining compliance & AML policies and procedures which would support the objectives and values of the Bank.
• Coordinate with relevant authorities on AML and CTF issues.
• Coordinate, design and implement FATCA regulatory requirements across all business units.
• Assist in KYC documentation integrity and update, client due diligence, Politically Exposed Persons (PEP) identification, screening and sanctions monitoring, transaction monitoring, and investigation and reporting of suspicious transactions.
• Work with the Compliance team to ensure that the Bank is aware on updated and new regulations.
• Assist in reviewing new products, policies, and procedures to ensure compliance with regulatory and internal policies and procedures.
• Carry out reviews and follow-ups as required by Regulators/Legal Authorities.
• Prepare various periodical/ad-hoc reports, as required by statutory authorities or management.
• Assist in providing Compliance/AML training to the staff.
As the Compliance Officer, I was responsible for developing, implementing, supervising and monitoring the Company's compliance program in addition to the execution of the compliance policies and procedures; and as the Risk Officer, I was responsible for monitoring and controlling the risk aspects of the company’s operations;
- Compliance Officer:
o Reviewed, monitored and supervised the risk based compliance program to ensure full compliance with regulatory requirements.
o Liaised with Capital Market Authority (CMA) on compliance and regulatory matters.
o Advised the management on compliance and regulatory changes, and assessed the impact on business activities.
o Designed and implemented various AML monitoring programs.
o Advised and supported the employees on compliance procedures in relation to their relevant function.
o Reviewed and updated the company's compliance related policies and procedures.
o Trained and educated employees on AML practices and compliance policies and procedures to carry out their functions effectively and efficiently.
o Reported compliance matters to the management and the Board on regular basis.
o Kept informed on industry changes, trends and best practices, and assess their potential impact on organizational processes.
- Risk Officer:
o Reviewed and assessed market and operational risks based on market conditions, regulatory requirements and the Company’s overall strategy.
o Recommended changes where needed in light of policies and risk appetite.
o Established and/or adapted from the group processes to assess risks associated with new initiatives (e.g., products, services, distribution channels) and applied changes to existing activities or products, and also, implementing controls to mitigate risks.
o Coordinated and monitored the company’s risk-related projects.
o Coordinated with department heads to ensure that operation manuals and procedures are updated on a regular basis in order to include controls on new risks related to new business processes, systems implementation/enhancement and regulatory requirements.
o Prepared an annual risk assessment plan.
o Provided support and advice to department heads in the identification of risks and their appropriate mitigation.
o Monitored, updated and reported to Management, Group Operational Risk and CISBC departments with details of incidents of significant events such as complaints, claims, errors, rule breaches, and fraud.
o Worked closely with internal audit, compliance and other key control functions for integrated control reviews.
Responsible for the development, implementation and supervision of risk and compliance procedures.
• Developed and implemented risk and compliance monitoring programs with business functions (brokerage, back office, front office and accounting).
• Trained personnel on operational risks and benefits of compliance.
• Supervised and monitored the implementation of Central Bank’s policies.
• Defined, monitored and reviewed processes to ensure compliance with regulatory requirements and updates.
• Identified, categorized and assessed the risks by business activity.
• Advised investment and risk committees on risks and strategies.
• Project-based: collaborated with CEO on restructuring the company by enhancing the existing workflow and drafting procedures.
Responsible of the creation and operations of the Back Office, Middle Office, and IT department.
• Reported directly to the Managing Director.
• Defined, supervised and coordinated the implementation of policies, procedures, systems and controls.
• Ensured the fulfillment of Central Bank’s requirements (focus: anti-money laundering and IT security protocols).
• Supervised the customization, implementation and testing of the core system (Omega) for Risk Management and control, and coordinated the interface with the accounting system.
• Conducted regular control on trading operations, clients' limits and margin calls, etc.
• Performed various monthly reconciliations: P&L, counterparties confirmations, rebates, commissions and spreads.
• Trained personnel on portfolio valuations, margin call calculations and requirements and Omega system.
Trainings: Omega Financial System, IT Infrastructure.
Responsible for supervising client activity and portfolio valuation
• Reported directly to CEO with various system reports (commissions, clients’ P&L, rebates, trading errors and trading activity assessment).
• Computed daily P&L and risk assessments.
• Clients’ relations: daily information on their margins and portfolio valuation.
• Monitored and recorded all executed trades in the system.
• Investigated trading errors and reported them to the relevant parties.
Trainings: Clients relations in Financial Institutions, Money Laundering Techniques (with the Central Bank), Client portfolio valuation.
Responsible for developing Payment & Cash Management solutions
• Reported to the Corporate Banking Manager.
• Reviewed customers’ product utilization and examined cross-sales opportunities with relationship managers.
• Online banking system: Implemented and tested HSBCnet prior to delivery in its various modules; migrated customer database from Hexagon to HSBCnet; and trained clients on using HSBCnet (achievement: Increased sales and adoption of HSBCnet by 50% in 2004).
• Assisted and trained clients on Hexagon and HSBCnet.
• Led the business re-engineering team in conducting various internal studies to optimize productivity and reduce costs.
Trainings: Clients relationship management, attitude and inter-personal relations, corporate social responsibility.
Responsible for the bank’s purchases and follow-up on daily operation
• Reported directly to COO.
• Developed and managed the day-to-day functions of the Bank’s operations.
• Coordinated with line managers to solve daily operation issues.
• Reviewed and planned the annual operating plan (AOP) by cost centre, aligning actual expenses to forecasts.
• Initiated and implemented conversion to a computerized “Assets Depreciation” system (achievement: over 15, 000 records in 3 months).
Masters degree II - DESS in Economics (equivalent to a Post-Masters degree) Emphasis: New Technologies in Information & Communication (NTIC)
Masters degree I in Economics Emphasis: New Technologies in Information & Communication (NTIC)
