Assistant Manager AML Investigation

Department

Compliance Department

Location

Sharjah, UAE

Job summary

To assume the position of Assistant Manager AML investigations and undertake AML investigations based on unusual transactions, suspicions or concerns identified through AML transaction monitoring, system alerts, compliance concerns, internal suspicions, or market intelligence in line with CBUAE regulatory requirements, FATF standards and the AML risk appetite of the bank. As a manager for the team, the role also entails mentoring, guiding, and supporting the compliance staff in the team in general and specifically any direct reporting staff (as applicable). It also entails providing guidance and expertise to the AML Investigation Team on research techniques, capabilities and systems. Acts on behalf of the Head of FCC in his absence in what is related to financial crime.

Duties and responsibilities

1) Management

1.1. Team lead

• Serving as the team lead and subject matter expert to ensure compliance with the applicable AML / CTF and regulations, assisting the DMLRO and MLRO in implementing the Financial Crime compliance program of the bank with a view to ensure meeting local regulatory requirements and industry best practice standards relating to Anti-Money Laundering (AML), Combatting Terrorist Financing (CTF) and Know Your Customer (KYC), and to provide guidance to the senior officers/officers in the team.

1.2. Management of Financial Crime Compliance Program / Plan

• Assisting in implementing an effective Financial Crime Compliance program (FCC program) covering mainly AML, CTF, sanctions and KYC. This includes developing, coaching and mentoring compliance staff on AML, KYC, CTF and sanctions matters to ensure that personnel are properly trained and equipped to undertake their jobs.
• Assisting in developing regular monitoring procedures and practices to assess the adequacy and effectiveness of internal systems of control and measures implemented by the bank.
• Assisting in developing and updating a regulatory and statutory reporting program and liaises with departments within the bank to ensure timely and accurate regulatory reporting.
• Identifying and recommending enhancements to workflow inefficiencies.
• Driving other change management initiatives emanating from the Compliance Plan, particularly those in the compliance technology space.

1.3. External liaison with regulator

• Assisting with regulatory queries, inspections, reports and requests to ensure these are managed effectively and professionally to maintain strong and healthy regulatory relationships.

2) Policy setting and advisory

• Assisting in reviewing all AML & CTF related policies, processes, and procedures to identify any gaps and address these to meet regulatory and best practice requirements.

3) Monitoring and reviews

• Acting as first level of referral for the AML unit team for discussion of cases, assistance in investigations or issues with business units, revision of STRs, etc., then make a clear determination regarding the appropriate steps around further regulatory reporting, escalation to management and potential exit of relationships prior escalating to DMLRO.
• Revising and allocation of AML transaction monitoring alerts and cases created in the AML transaction monitor system. Undertaking manager review of completed cases and as required, decide as to whether or not a STR should be filed within the regulatory TATs.
• Performing in-depth expert analysis, review and investigation of unusual transactions, suspicions or system-generated alerts as highlighted through internal systems, reports, staff, regulators or market intelligence.
• Ensuring immediate action and follow-up until satisfactory closure to address CBUAE comments/requirements.
• Performing proactive, risk-based AML monitoring and trend analysis to identify any links between identified suspicions, concerns, unusual activity and customers to protect the bank from risk associated with potential inter-related criminal activities and money launderers.
• Identifying and suggesting improvements to the AML transaction monitoring process, scenarios, rules and methodology based upon investigations, trend analysis and international best practices.
• Taking proactive steps and remaining aware of market trends and industry expectations around AML to identify money laundering trends and typologies and suggest techniques for prevention and mitigation of ML/CTF risks to the bank.
• Providing feedback to AML senior officers / officers regarding the quality of case work performed while ensuring adherence to internal procedures.
• Provide oversight of the investigation process from point of initial detection to disposition of the investigation.
• Collaborating with the Fraud Department / Unit to support joint execution of both major cases and fraud investigations.

4) Management information and reporting

• Where suspicions are identified and investigated and where reporting is required, prepare a detailed Suspicious Transaction Report (STR) in line with CBUAE guidelines and expectations, ensuring appropriate coverage of the relationship, suspicious activity, any potential links to other relationships, identified AML typologies, and efforts made to substantiate the suspicions and concerns identified in the STR.
• Assisting in developing FCC management information, reports, trends analysis and typologies to identify and anticipate areas of concern in AML, KYC and CTF as well as recommending appropriate actions or decisions to properly address the risks.
• Maintaining appropriate MIS (daily, monthly, quarterly, annually) of alerts, investigations and STR filed and the responses received from Central Bank as well as any action required and follow up or escalation.
• Monitoring and administering the daily, weekly and monthly MIS that reflects team and individual performance numbers and take appropriate initiatives to adhere to goal and expectations.
• Assisting with monitoring and ongoing feedback loop to the business lines to improve knowledge, awareness and reporting of financial crime risks to the AML Investigation Team for investigation.
• Escalating in a timely manner any potential significant risk issues found during an investigation to the DMLRO and Head of FCC and other stakeholders in the bank, as the case may be.
• Ensure thorough documentation of the suspicious transaction reports numbers and decision-making process.
• Providing additional support in relation to the annual risk assessment process and conducting FCC risk analysis.

5) Training and awareness

• Assisting in developing an effective training program in accordance with the annual Training & Awareness Plan.
• Assisting in planning, establishing / creating comprehensive AML, sanctions and KYC training content (including e-learnings, face-to-face or virtual, as the case may be), as well as conducting bespoke training on a needs basis to targeted audiences in addressing associated identified risks and ensuring ongoing awareness and appreciation around related compliance trends, developments and risks.
• Assisting the Head of FCC in preparing and / or providing training to Senior Management / BOD.
• Liaising with external parties / service providers (as the need be) for e-learning courses or other types of training.
• Enhancing the compliance internal page and providing constant updates to spread awareness to the bank staff.
• Ensuring the necessary level of understanding and awareness of AML, KYC, CTF and sanctions amongst management and staff by ensuring training on AML, KYC, CTF and sanctions.

6) Systems and technology

• Periodically reviewing and testing the AML systems and reporting results and recommendations to Senior Manager FCC and Head of FCC as required.
• Ensuring proper follow-up with the relevant team members, IT and Project Managers for any identified gaps or on any ongoing projects.
• Establishing and providing comprehensive informative management information analysis and reports.
• Advising on enhancements of the existing systems or on introducing new scenarios.

7) Independence of operation

• Works as subject matter expert in AML investigations and regulatory reporting to the CBUAE under oversight of the line manager. Initiates investigations on a proactive basis, identifies trends to mitigate risks and further identifies opportunities to improve the bank's compliance control framework.

8) Accountability / decision making

Full accountability for the in-depth AML analysis of suspicions and concerns and onwards regulatory reporting to the CBUAE. Responsible for deciding on AML concerns to ensure appropriate reporting and risk mitigations to prevent the bank from being abused by money launderers. Management and stakeholders are advised of concerns, recommendations are made and follow through is undertaken to ensure the appropriate corrective action is taken as required in line with the risk appetite of the bank. Presents inputs and suggestions for improvement of Compliance AML policies and procedures.

9) Communication with

• Head of FCC / Department / Department Staff - Accountable subject matter expert on investigations highlighting typologies and trends, providing feedback on progress, recommending actions, escalating concerns.
• Bank Staff, Management and Senior Management - Serve as subject matter expert on AML, CTF and sanctions matters. Provide necessary updates on trends and typologies to assist in managing associated risks. Ensure necessary training and awareness.
• Central Bank / Regulators / Authorities - Submission of STR and follow up on any action required. Undertaking prescribed regulatory Enhanced Due Diligence requests as and when needed.

Required skills & qualifications

• Tertiary education with a bachelor's degree as a minimum.
• Any compliance qualification or certification, such as ACAMS and/or CFCS certifications or any other relevant AML/compliance qualifications from an internationally recognized body.
• Minimum 8 years' experience in a banking / financial institution environment of which 5 years' experience should have been in AML investigations or similar department.
• In depth knowledge of CB UAE and other related AML / CTF regulations.
• Analytical, investigative, problem solving and decision-making skills.
• Attention to details.
• Independent and self-starter.
• Organizing skills.
• Strong team player.
• Good written and oral communication skills.
• Good time management skills and adherence to deadlines.