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26 Apr 2024

Expert, Financial Crime Compliance Governance and Policy (40001521)

Category:  Corporate Affairs Division
Job Type: 
Facility:  Corporate Affair

Job Purpose

1) Establish and maintain an effective and coherent Financial Crime Compliance Governance system to prevent risks to banks
2) Ensure the development and enforcement of Financial Crime policies, regulations and procedures in accordance with legal regulations, international standards and risk appetite of TCB 
3) Promote a culture of compliance, proactively identify and prevent employee risks across the entire line of FCCM

Key Accountabilities (1)

1. Develop, maintain and manage effectively FCC governance framework
- Develop/update risk indicators/compliance to prevent financial crimes in accordance with the Bank's risk strategy, appetite and risk tolerance.
- Monitoring risk indicators/compliance against financial crime to ensure compliance with the risk appetite of banks 
- Develop, maintain and improve the operating model, governance, compliance, financial crime prevention and related initiatives to comply with the law and towards leading practices; 
- Supervise and evaluate the effectiveness of the implementation of the operating model, governance, compliance, prevention of financial crime and related initiatives;
2. Govern internal and external FCC reports 
- Perform FCC risk assessment annually as required by regulation, to ensure the bank can define appropriate requirement of measures & controls to manage FCC residual risks. 
- Monitor and report the status of risk indicators/risk portfolio as well as compliance of FCCRM across the bank wide to the Board of Director/BOM/Risk Committee
- Consolidate and review Report FCCM activities and MIS report to CEO and related Board/Management Risk Committees periodically or ad-hoc
- Consolidate and review Report as required by laws/regulators; internal regulations related to FCCM activities
- Handle and support business in the requirements of the Inspector, audit ... related to the content of FCCM

Key Accountabilities (2)

3. Develop and control FCC policy & procedures
- Develop, review and update annually and unexpectedly FCC policy, regulations and processes and relevant documents to ensure compliance with regulations and requirements of laws and international practices in line with bank’s risk appetite
- Develop, review and update periodically FCC risk assessment ​​methodology and related procedures; models for assessing and monitoring the risk of money laundering
- Provide policy of applicable watchlist and watchlist management mechanism
- Review and monitor reports at the request of SBV are fully and timely implemented 
4. Provide FCC advisory
- Provide independent FCCM advisory related to designs and implementation across the bank-wide
- Identify, evaluate and recommend measures to control and mitigate risks of FCCM
- Provide independent comments and consult of FCCM elements in relation to related procedures/processes/new products / new market entries/new emerging risks and recommendation for approval in order to deploy the bank's policies and standards properly and consistently 
- Review advice of Senior Officer/Officer 
 - Act as the focal point to answer and take responsibility for the consulting content before providing it to the relevant units
 - Ensure consulting activities are carried out within the scope of the SLA and up to the standards 

Key Accountabilities (3)

5. Develop, maintain and ensure FCC Competency framework
- Responsible for developing, maintaining the FCCM competency framework and training roadmap for positions/functions throughout the bank 
- Responsible for developing and implementing FCCM training program and competencies assessment for all level/positions annually to update, drive new requirements
- Responsible for promoting and implementing the enhancement of awareness/ communication programs, change management of FCCM
- Conduct evaluation reports and recommendations related to implementation programs 
6. Perform other duties as assigned by management

Key Relationships - Direct Manager

Director, Financial Crime Compliance Governance and Policy

Key Relationships - Direct Reports

Key Relationships - Internal Stakeholders

-  Departments of FCCM
- Departments of Corporate Assurance, Departments of Corporate Affairs
- Other related Division, Departments in the Bank 

Key Relationships - External Stakeholders

- The State Bank and other regulatory agencies, financial information analysis units;  Police
 - Industry partners / Correspondent banks / International organizations 

Success Profile - Qualification and Experiences

- Graduated from university majoring in Law, Economics, Foreign Relations, Finance - Banking, Business Administration

- Experience: Minimum 8 years of experience in the field of AML 

- Foreign language (English): Use English fluently.  Minimum TOEIC 650 or equivalent 

- ACAMS /Advanced CAMS

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