Senior Manager, Financial Crime Compliance

CRDB Bank

Dar es Salaam

Job Description

JOB REPORTING TO : Head of Compliance and Governance

JOB PURPOSE

The Purpose of the job is to support and define the bank’s AML & Sanctions Monitoring strategy and goals across the bank, guiding the program. To ensure the bank has relevant, up-to-date, and adequate policies, procedures, processes, and strong controls to support the management of Financial Crime Compliance (FCC) Risks; FCC risks include Money Laundering, Terrorism Financing, Sanctions, and Anti-Bribery & Corruptions Risks. Oversee the first line of defense in implementing the requisite AML & Sanctions controls, processes, and systems to comply with applicable laws, rules, and regulations, as well as frameworks, policies, and procedures.

KEY RESPONSIBILITIES:

FCC Program Management

• Champion effective implementation of methods to identify, assess, and mitigate AML/CFT/CPF, and Sanction risks across the Group.
• Provide oversight and support to the bank’s Compliance Risk Infrastructure that monitors Suspicious Activity, AML, and Sanctions violations.
• Harmonize to the greatest extent possible AML & Sanctions Compliance policies, procedures, and Risk Assessments across the Enterprise.
• Design and support implementation of Enterprise KYC/CDD programs consistent with AML regulatory requirements and the bank’s specific risk profile.
• Conduct examinations and assessments of the bank’s AML/CPF/CFT and Sanctions Compliance programs:
• Develop an annual schedule and continuous process for compliance testing and monitoring activities across all business line functions.
• Oversee and ensure the production of timely and effective AML, Sanctions, and Transaction Monitoring-related MIs and other applicable information to the Director of Risk & Compliance, Management Operational
• Risk Committees, and Board Risk Committee.
  Support the design, development, and implementation of strategies, standards, and procedures to support the AML/CFT/CPF Data Governance program while facilitating adherence to the bank’s Enterprise Data
• Governance framework for data policies, standards, and practices.

Enterprise Risk Assessment & Control:

• Provide oversight to the bank’s Compliance Risk Infrastructure: Safeguarding operational and compliance risks governance, policies, and standards are enforced by all lines of businesses and support units.
• Participate in Annual Compliance Risk Assessments – play a key role in the assessment through all stages.
• Provide quarterly risk assessment and updates to the Board and management on the closure of audit issues.
• Review new products and services to ensure appropriate consideration of key AML/CFT/CPF and Sanction compliance risks and any necessary mitigating controls.
• Implement and coordinate Compliance Risk Management Processes while challenging the First Line of
• Defence (FLOD) on the effectiveness of controls: Drive finalization of risk category and subcategory framework for Risk and Control Self Assessments, Product Risk Assessments, and Process Level Assessments.
• Design and implement Risk Based Alerts Scoring Models: Lead the development and maintenance of the
• Enterprise AML Transaction Monitoring strategies, including scenario development and rules optimization to support AML and Forensic Risk Identifications.
• Design and Implement vendor’s due Diligence Framework: Develop vendor’s risk categorizations and implement Due Diligence commensurate with risk levels.
• Consistent with AML regulations and policy recommend De-Risking initiatives to management based on increased customers’ or Product Risks Profile against established bank’s AML risk appetite.
• Design risk-based Financial Crime Compliance Training and ensure training requirements are implemented across the group by staff.
• Perform other duties as assigned by the Head of Compliance & Governance.

EDUCATION REQUIREMENTS EXPERIENCE, KNOWLEDGE, AND SKILLS REQUIRED

• Degree from a reputable University preferably in Law, Economics, Finance, Risk Management, or a related discipline.
• Holder of ACAMS Certifications or intention to be certified within six months of employment.
• 7 + years of experience in the banking industry or regulatory environment; at least 5 years in AML/CFT and OFAC/ Economic Sanctions compliance.
• Experience in dealing with regulatory matters and confident interaction with Management, Board, and Regulators.
• Significant experience in Risk and Operations Management together with business management, from a frontline role in Commercial Banking
• Ability to identify, escalate and communicate issues to management in an effective and succinct manner
• Strong knowledge of AML laws & Sanctions regulations and their application.
• Excellent project management and organizational skills and capability to handle multiple projects at one time
• Advanced knowledge of Excel, Access, Word, PowerPoint, and Projects.
• Excellent written, and verbal communication, and analytical skills
• High level of moral and Ethical standards Generally applicable to the bank

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