FCC Governance & Controls - Senior Compliance Officer – Sanctions Expert

Publiée le 07/04/2024

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FCC Governance & Controls - Senior Compliance Officer – Sanctions Expert

Role & work environment

Financial Crime Compliance (FCC) Governance & Controls Luxembourg is the second line of defence function supporting ING Luxembourg, its underlying entities and the Anti-Money Laundering (AML) Compliance Manager in managing the FCC risks.

The Governance and Controls function includes oversight of 1st line of defence AML related processes & sourced activities, the monitoring of customers’ activities (aka Transaction Monitoring) as well as the investigation of atypical & complex cases regardless of the source of identification (Adverse Media Screening, Transaction Monitoring, Name Screening, …) and the handling of special requests (Police, FIU, ...).

The mission of Governance and Control team aims to identify and report on emerging threats and risks stemming from known and evolving forms of Financial Economic Crime (FEC), such as money-laundering, terrorist financing, corruption, and transnational and organised crime.

The team is working together based on knowledge and expertise, as well as the skill set needed to best perform the job.

You report hierarchically to the Head of the FCC Governance & Controls, who reports to the Head of Financial Crime Compliance, being the Anti-Money Laundering Compliance Manager of ING Luxembourg.

Key responsibilities

The role of the FCC Governance & Controls Senior Compliance Officer is critical for the Bank’s defence against money laundering, terrorist financing and fraud.

As a senior expert with a strong focus on Sanctions, you take part in the execution and further development of the anti-money laundering strategy of the Bank by reviewing client’s profile and transactions, reporting unusual transactions, analysing trends and providing input on emerging risk or risk typologies to strengthen the existing risk control framework. Next to this, you will ensure adequate reporting towards internal & external clients and take the lead to convert the outcome of your investigations, trends analysis and quality controls into pro-actively sharing of lessons learned and defining & implementing the training needs for 1st and 2nd line of defence colleagues on emerging risks, typologies, best practices, do’s and don’ts.

You will be responsible for the following (non-exhaustive) overview of activities:

  • Review Financial Crime Compliance alerts escalated by 1st line of defence or other compliance teams, which includes Transactional Monitoring alerts (especially in the framework of Pre-Trade Screening) or any other Unusual Activity Reports (atypical cases) or requests for analysis received, in line with prescribed procedures and determine whether transactions occurring are valid Anti-Money Laundering (ML), Terrorist Financing (TF) or Sanctions Evasion risks by:

  • Evaluating transactions and customer relationships for ML/TF/Sanctions activities, identifying red flag issues & potential suspicious activities and performing in depth-investigation within the FCC framework when needed;
  • Handle periodic and immediate Name Screening cases (PEP/TER);
  • Effectively communicating with business lines and/or Safe Business Officers to obtain additional information and documentation as needed;
  • Preparing suspicious transaction report & suspicious activity report (SAR) filing;
  • Maintaining accurate and concise records of all investigations undertaken including details on the rationale for any decisions made;

  • Ensure adequate follow up by 1st line of defence of alerts / cases investigated by FCC Governance & Controls function;

  • Monitor the queues for alerts for ensuring adequate management of outstanding alerts and prioritization rules;

  • Ensure the creation and maintenance of the procedures and WPI of the team and sourced FCC activities; challenge the 1st line of defence procedures and WPI’s (incl. training & instructions) on AML-related processes;

  • In close collaboration with colleagues of other compliance teams, promote/enhance the knowledge and awareness with regards to FCC within the organisation;

  • Represent the FCC Governance & Controls team in projects, workgroups by coordinating, providing input, defending his/ her position, challenging the discussions and communicating the output to the members of the team;

  • Identify key areas for improvement and provide support and guidance to implement good practice;

  • Drive the implementation of automated process, robotics or data analytics techniques in order to maintain the efficiency of the FCC compliance related processes and tools;

  • Be a support, coach and trainer for your less experienced colleagues of 1st and 2nd line of defence by defining and working out their training needs;

  • Any other associated duties required from time to time to meet the teams mission and targets.

Key Competences

A colleague with a talent for taking it on and making it happen, enthusiasm for helping others to be successful and a knack for always being a step ahead. In other words, you strive to bring fresh ideas to life and embrace challenges in a fast changing and complex environment. You are a naturally collaborative person who listens and invests in others to achieve common goals. You love to challenge the status quo and are eager to propose creative solutions to problems.

As a FCC Governance & Controls Senior Compliance Officer you will also need:

  • A master degree in Law, Economics or equivalent in experience;
  • More than 6 years’ work experience in the banking world, with proven knowledge in the FCC domains or equivalent, with at least 5 years in an investigations role in an FCC relevant environment; ACAMS Sanctions certification is a plus;
  • Very good knowledge and expertise of Sanctions matter
  • Very good knowledge on the industry trends and ever changing FCC compliance regulations & procedures ;
  • Strong analytical skills, interest for data (analysis) and the way to process them, as well as a keen eye for detail;
  • Capacity to understand the main points of risk for the Bank specifically in relation to Customers and transactions and the overall risk tolerance of the Bank;
  • Ability to recognize suspicious transactions, investigate risk-based any unusual activity and to prioritize the in-depth reviews;
  • Strong and effective communication skills – fluent in written and spoken English and French;
  • Very good knowledge of Excel, Powerpoint, knowledge of other software application is a plus;
  • Able to use different communication styles fitting with the need of the (internal) customer, both verbally and written;
  • Being able to quickly integrate new concepts, procedures, modifications in the organisation or methodologies;
  • Good skill set in the areas of personal effectiveness (i.e. autonomy, team spirit, courage and self-confidence, problem solving & result oriented by delivering as promised within tight deadlines, “hands-on”, good written and oral communication, capable to work in changing circumstances, customer focus and investigative & learning ability).

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FCC Governance & Controls - Senior Compliance Officer – Sanctions Expert

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