Head of FCC Governance & Controls Expirée

Publiée le 06/02/2023

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ING Luxembourg

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Head of FCC Governance & Controls

Your 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, Prosecutor, 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 Luxembourg.

Your key responsibilities

The role of the FCC Governance & Controls Investigator is critical for the Bank’s defense against money laundering, terrorist financing and fraud. As a senior expert with a strong focus on investigation, 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:

  • Lead FCC Governance & Controls team :
    • Steering of the compliance activities in the FCC Luxembourg area with the help of a team of compliance advisors and analysts;
    • Ensure the continuous development of compliance knowledge and expertise within the FCC team and contribute to the same within the wider ING compliance community;
    • Create a productive and constructive collaboration and exchanges within the team as well as with other compliance teams
    • Support the team members in the execution of their activities; take as a content matter expert final decision when needed;
    • Cover all HR related activities, including performance management;
    • Contribute to FCC Lux dynamic planning.
  • Review Financial Crime Compliance alerts escalated by 1st line of defence or other compliance teams, which includes Transactional Monitoring alerts 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 (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;
  • Ensure the 4 eyes on cases handled & SARs prepared by less experienced colleagues;
  • Monitor the queues for alerts for ensuring adequate management of outstanding alerts and prioritization rules;
  • Perform trends analysis, investigation of complex / special cases (FSMA/NBB requests; request for information from FIU/Police/Prosecutor…);
  • Provide guidance, insight and investigate alerts escalated to 2nd LOD in the framework of lookback exercise;
  • 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;
  • Provide advice and support to the Bank’s business units on a case by case basis, when needed and support these units on the identification of areas of risk as a result of transaction monitoring trends and other in-depth investigations and trend analyses;
  • Ensure continuous quality controls on the full E2E AML-processes, including process steps performed by 1st line of defence and sourced activities as well as on own activities;
  • 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;
  • Support the head of FCC Governance and Controls actively in the preparation of clear and convincing compliance risk management and management information reporting in all its forms (e.g. NBB/DNB questionnaire, AML & Compliance report, etc) by ensuring data gathering and consolidation of all information acquired;
  • 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.

We look for

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 Head of FCC Governance and Control 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 certification is a plus;
  • Team manager experience (the job holder will manage FCC Governance and Control team composed of 10-15 FCC experts);
  • 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;
  • A team player with strong interpersonal skills who is able to build effective working team and relationships within a diversified and multicultural work environment; You inspire, motivate and help others to succeed;
  • 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).

We offer you  

A clear purpose, a unique offer and a range of flexible compensation and other benefits:

  • Personal growth & challenging work with endless opportunities to realise your ambitions
  • An informal, dynamic environment with innovative colleagues supporting your endeavours
  • A progressive and agile way of working, where new ideas are valued ahead of convention

Furthermore, within the Compliance department, you can count on a range of opportunities to invest in your personal and professional growth with:

  • the possibility to participate in many different courses and trainings
  • the opportunity to interact with many key internal and external stakeholders

Your working environment at ING:

With over 1000 employees in the Grand Duchy and thanks to the combination of our local presence and the strength of a robust multinational like ING, we offer our personal and business customers a wide range of solutions through the channel of their choice.

ING is a global bank with a strong European base. 53,000 employees serve around 38.4 million customers, corporate clients and financial institutions in over 40 countries. Operating in the Grand Duchy of Luxembourg since 1960 as a universal and accessible bank, our products include savings, payments, investments, loans and mortgages for retail and private banking customers, whom we sever serve online and through our network of branches. For our Wholesale Banking clients, we provide lending, sustainable finance, payment & cash management, and fund services.

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