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FCC Sanctions Officer

HSBC Private Bank (Suisse) SA
Date de publication


FCC Sanctions Officer

Role Purpose
  • Accountable for ensuring that PBRS (and other Swiss legal entities of HSBC – together `PBRS`) does not breach any trade, economic and financial sanctions as implemented by, inter alia, the USA, UN, EU, UK and Switzerland, and that any risk of a possible breach is mitigated.
  • To monitor key regulatory and Group Standard changes pertaining to sanctions issues, and to proactively communicate with business, compliance et al, in order to implement such changes as necessary to ensure compliance with developments.
  • Investigate sanctions alerts escalated to Financial Crime Compliance
  • Conduct detailed client reviews to establish the client’s exposure to  sanctions, where required by regulations and policy
  • To collate and report information regarding PBRS’ exposure to and follow-up of sanctions issues and record any potential breaches of sanctions from across PBRS, as part of regular reporting or on an adhoc basis.
  • Act as a point of contact within Compliance for business and other Compliance personnel in relation to sanctions risk, including contact with Swiss regulators where required.
  • Construct and present training material for sanctions related topics to both business and Compliance. 
  • Provide advice to business and Compliance on risk associated with prospective business, products and service and design mitigation controls and implement strategies as appropriate
  • Provide support so that IT tools and processes are fit-for-purpose and continuously enhanced to reflect changes in Group Standards and applicable regulations
Principal Accountabilities:
  • Support FCC Operation (HOST) department in charge of level 1 & 2 Customer and Transaction screening
  • Support and facilitate implementation of an effective Sanctions controls framework.
  • Support Financial Crime Compliance management in discharging the relevant accountabilities as set out in the Group Financial Crime Compliance standards framework.
  • Manage the required remedial action of all material FCC sanctions issues that arise, to ensure effective adherence to sanctions regulations and minimise the potential of any adverse exposure.
  • Conduct systematic reviews of the PBRS client base to identify potential sanctions breaches and related issues.
  • Develop and deliver training on sanctions and sanctions risks.
  • Ensure level 3 alerts are treated in a timely matter.
  • Local standards and policies are maintained to accord with changes in Global policy
  • Clear, accurate and timely advice provided.
  • Track the strategic implementation of an effective Sanctions controls framework.
  • Monthly reviews and ongoing monitoring activity to ensure satisfactory completion of requirements.
  • Accurate and timely implementation of IT system changes (in coordination with GPB Compliance)
  • Ensure that standards, policies and procedures meet regulatory needs and are clearly understood by stakeholders.
  • Adverse consequences arising from FCC Sanctions breaches/issues are managed, mitigated and reported, with remedial action initiated in line with the materiality of the risk/issue.
  • Ensure client reviews are conducted in a timely matter and documented accordingly, as described by policy
  • Communication of clear training requirements.
  • Liaise with relevant stakeholders within PBRS to provide expertise and support on all Financial Crime Sanctions related matters.
  • Support FC Compliance management with the provision of reports on sanctions issues.
  • Ensure that FC Compliance management is appropriately advised of material sanctions issues.
  • Work effectively with local regulators on sanctions matters.
  • Liaise with GPB and Group Compliance on policy matters
  • Clear direction/advice/guidance given in a timely manner.
  • Provide reports to senior management on significant issues in a concise and timely manner.
  • Ad hoc reports to senior management on significant financial crime and reputational issues are provided as they occur, within agreed timescales.
  • Provide report to regulators as appropriate and required on sanctions related issues
  • Constructive working relationship with GPB and Group Compliance
 Leadership and Teamwork
  • Ensure Group sanctions policies are properly integrated in to PBRS’ DIMs and other documents.
  • Provide the appropriate level of guidance and assistance to other Compliance personnel and elsewhere within PBRS for sanctions issues.
  • Promote and enfoster where possible a culture of adherence to Global and regulatory rules and policies for sanctions.
  • Maintain and develop a positive and professional working relationship with business managers and Relationship Managers.
  • Strategies and policies to be developed and communicated clearly and in a timely manner.
  • Contact maintained with key business personnel and to update on sanctions developments, when appropriate.
  • Demonstration of Group Values in all behaviours.
  • Strategies and policies to be developed and communicated clearly and in a timely manner.
 Operational Effectiveness and Control
  • Be creative/innovative in implementing policies
  • Ensure all local policies and dispensations, etc. are updated for changes in Swiss regulation and impacts on business.
  • Maintain awareness of operational risks and seek to minimise the likelihood of any sanctions breach occurring, including its identification, assessment, mitigation and control.
  • Ensure timely and accurate escalation of sanctions related issues to the Head of FC Compliance, as required.
  • Clear risk-based policies/advice produced.
  • Compliance plans in place across the FCC function to agreed timescales.  
  • Review below standard audit reports and take the appropriate action to remedy any identified deficiencies.
 Major Challenges
 To take the complex regulatory sanctions environment, to understand the pragmatic implications of these regulations and communicate HSBC’s interpretation to the relevant stake holders in PBRS, to ensure that the risk of PBRS committing a sanctions violation is materially eliminated.  Further, to remain vigilant in monitoring changes to the political and regulatory environment and proactively manage any potential impact on business. 
To be in a position to provide practical and pragmatic advice to live sanctions related issues, but to ensure effective communication is maintained with Sanctions management to solicit additional guidance or advice where required.
Role Context
The role holder is required to work with material autonomy, dealing with significant issues for which there is no clear cut solution, but to ensure that substantial sanctions related topics or issues are escalated and reported to the PBRS Head of Sanctions and other management as required.   It is also expected that a close working relationship is maintained with the Group or Regional sanctions teams to ensure PBRS is kept apprised of any material changes.
Knowledge & Experience / Qualifications
  • Extensive knowledge of Sanctions regulations and guidance.
  • Significant experience in the financial services industry.
  • Lateral thinker with an ability to interpret and solve complex issues.
  • Excellent communicator with strong inter-personal and influencing skills.
  • Experience of dealing with regulatory matters and interaction with Regulators.
  • Ability to develop practical, cost effective solutions to complex global issues
  • Both spoken and written communication skills with the ability to document investigative steps and conclusions effectively, in a clear, concise and professional manner
  • High level of proficiency in English, both spoken and written.

 Please apply via our career website