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AML Senior Manager

HSBC Private Bank (Suisse) SA
Date de publication


AML Senior Manager

Role Purpose
  •  Assist in the development and implementation of group-wide policies & procedures and ensure compliance at regional and country level.  Participate in Global/x-LOB Working Groups to ensure that GPB and its interests are represented and considered in developing new standards, policies and procedures.
  • Assess, analyse and interpret Group policies from a GPB perspective, determine their impact and coordinate implementation across GPB.  Write GPB specific guidance where Group policies may not fit the LoB Business Model so that the business can implement pragmatically.
  • Provide guidance and advice to GPB Entities on the application and implementation of FCC policies.
  • Participate in the design of training material to promote FCC awareness, undertake training as relevant
  • Identify, escalate and report on material issues arising with respect to the implementation of policies in GPB.  Manage all exceptions, variances, dispensations from GPB FCC Policies and the approvals workflows and reporting.
  • Work with the Global Standards team and other stakeholders to develop standardised FCC related requirements for GPB, including in conjunction with other relevant subject matter experts (“SME”) from other Business Lines; take part in Policy clinics/working groups.
  • Manage, as necessary, relevant FCC Practice Teams: organisation, management of meetings, action management, translation into proactive issue management and necessary policy revisions.

Principal Accountabilities:

Impact on the Business/Function
  • Contribute subject matter expertise on agreed aspects of Global Standards requirements, participate in Group workstreams, representing the GPB position in line with agreed guidelines
  • Engage with other LOBs around the consistent translation of bank-wide requirements into GPB policy, user guide/FAQs and training updates
  • Continuous review for appropriateness of  policy framework for GPB
  • Provision of FCC advice and guidance for business specific or global initiatives.
  • Discharge the relevant accountabilities as set out in the Group Standards Manual and Compliance FIM.
  • Adherence to timelines for delivery of results
  • Appropriate and timely advice is provided to the business
  • Compliance risks are managed by appropriate policies
  • Accountabilities fully discharged.
Customers / Stakeholders
  • Support GPB FCC management  in the provision of reports for GPB or Group Management, as necessary
  • Ad hoc reports to senior management on significant financial crime and reputational issues are provided as they occur, within agreed timescales.
  • Liaise with GPB Entities with regard to requirements emanating from  Global Policy & Standards work
  • Provide advice, support issues arising from implementation of GS
  • Regular reports are prepared and presented within agreed timescales, with explanation to relevant body.
  • Ensure proper communication both up and down the reporting line. 
  • Adherence to timelines for delivery of results
  • Appropriate and timely advice is provided to the business
Leadership & Teamwork
  • Support GPB FCC management, in developing, setting and delivering consistent policies & procedures in line with Global Standards.
  • Help develop and implement training programs for financial crime  related issues for GPB FCC teams globally.
  • Develop and maintain productive relationships with GPB Entities FCC Heads and their teams
  • In conjunction with relevant colleagues, strategies and policies to be developed and communicated clearly and in a timely manner
  • Aid the development and delivery of relevant training.
  • Close working relations maintained with relevant colleagues within the Region and elsewhere.
Operational Effectiveness & Control
  • Ensure Group policies and practices are communicated and implemented across GPB, engaging with relevant stakeholders as necessary.
  • Be creative/innovative in implementing policies and providing solutions to complex global issues/initiatives.
  • Ensure appropriate reporting of any Global Standards or FCC advisory related issues
  • Any significant compliance issues reported appropriately and in a timely manner
  • Notifications and requests actioned on a timely basis, with appropriate conflicts and other checks undertaken.
  • Completion of all mandatory training courses
  • Internal efficiency and effectiveness
Major Challenges
Support GPB FCC management in understanding and achieving a balance between the demands of regulators, external bodies and governmental initiatives by making the voice of GPB heard in x-LOB Group Standards work and translating expertise into coherent policy development, guidance on the implementation of those policies and controls and systems to manage GPB-specific risks.
Role Context
The role will report to the Head of GPB Policy & Standards. The jobholder is required to work with considerable autonomy though with the guidance of Head of GPB Policy & Standards, dealing with major issues for which there is no clear cut solution whilst still being able to provide judgement and clear direction. Where items of major consequence are involved, reference is made to the relevant Global Functional Head.
Management of Risk
The jobholder is responsible for ensuring that the compliance and reputational risk standards are in accordance with the Global Standards Manual and the Compliance FIM are effective and relevant. Any FIM or Compliance policy dispensations must be formally reviewed and presented to the relevant Global Function Head for approval.
Observation of Internal Controls
  • Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.
  • Jobholder is an ‘insider’ for dealing purposes and subject to strict controls and confidentiality.
  • Discharges the Compliance Officer accountabilities set out in the Compliance Officer Handbook by pro-actively assisting management in identifying and containing compliance risk; monitoring, reporting and certification; fostering a compliance culture and optimising relations with regulators.
Knowledge & Experience / Qualifications
  •  Significant FCC Policy experience: drafting and strategy of implementation, experience of  working with multiple stakeholders and in a matrix management environment beneficial
  • Significant knowledge of compliance/AML, CTF and sanctions and other financial crime and regulatory compliance risks.
  • 5-7 years’ experience in the financial services industry, specific knowledge of private banking a significant asset
  • Policy Advisory experience: ability to give clear guidance on complex Policies
  • Organised, capable of digesting complex information and rendering it into summary of issues and recommendations, pragmatic approach to policy and stakeholder management
  • Team player, analytical, ability to perform under pressure and independently, resilient and able to deliver on time
  • Lateral thinker with an ability to interpret and solve complex issues.  Decision making capability.
  • Excellent communicator with strong inter-personal skills.  Experience of training development and delivery an asset
  • Ability to adopt a tailored and effective communication style to varying levels of management up to and including Senior Management

 Please apply via our career website