To support Bank management in the identification and management of compliance risk as required by relevant regulatory, supervisory and statutory regulations/guidelines, applicable codes of conduct and minimum standards.
Key Responsibilities/Accountabilities
1. Facilitate customer due diligence review on a regular basis;
This entails;
a) Monitoring transactions generated by customers to identify suspicious transactions.
b) Ensuring that branches review and close AML alerts generated.
c) Handling escalated alerts timeously.
d) Receiving of suspicious transaction reports and conducting a first level review with subsequent escalation to Money Launder Reporting Officer (MLRO) for reporting to the Financial Reporting Centre.
e) In liaison with business units, on an on-going basis conduct review of customer categorization to ensure accuracy in categorization and generation of quality alerts;
f) In liaison with business units, conduct periodic client reviews for high, medium and low money laundering risk accounts;
g) In conjunction with the Money Laundering Compliance Officer conduct annual review of thresholds for transaction monitoring.
2. AML Governance
Review AML/CFT policies, standards, procedures and processes and ensure they are implemented effectively, including customer acceptance policy, customer due diligence and record keeping.
3. AML Risk Assessment
a) Analyse potential money laundering and financing of terrorism risks associated with specific customers, products, jurisdiction and channels of delivery.
b) Analysis of key risk indicators in Anti Money Laundering/Combating of Terrorism Financing (AML/CFT)
c) Regular review of AML/CFT risk assessment methodology
d) Undertake enhanced measures to manage and mitigate AML/CFT risks where higher risks are identified;
4. Conduct AML/ CFT Compliance training.
This entails:
a) Conduct at least one training sessions for branches per calendar year focusing on AML/ CFT;
b) Provide annual training review report to the Money Laundering Reporting Officer (MLRO) as per the format provided;
c) Serve as a central point for reference for information on AML/ CFT measures and practices; and
d) Cascade changes in AML/ CFT requirements to teams and identify compliance challenges and escalate the same to Money Laundering Compliance Officer.
e) Ensure materials for AML/CFT on-line training are applicable and up-to-date.
f) Maintain up-to-date register for training attendance.
5. Screening of customer names (SDN alerts) in AML automated system entailing:
a) Review and resolution of real time detection alerts generated by the monitoring system;
b) Review of Special Designated Nationals (SDN) alerts generated by AML automated system;
c) Escalate to MLRO any true matches generated from the screening for reporting to the Financial Reporting Centre (FRC);
d) Recommend to MLRO for “whitelisting” of known false matches; and
e) Quarterly review of “whitelisted” accounts to assess if they still qualify for “whitelisting”.
6. Sanction Screening:
a) Weekly (or as per ad hoc changes) update of the caution list with latest UN, OFAC,HMT, EU among others.
b) Monthly update of caution list with Credit defaulter’s data.
c) Escalating sanction query to Group Sanction Department timeously.
d) Ensure the sanctions briefs are updated on the compliance website once they are released.
e) Compiling monthly Fircosoft reports for reference and track.
7. Management of Correspondent Banking relationship entailing:
a) Completion of AML questionnaires for our Correspondents clients;
b) Providing of AML pack for establishment of correspondent banking relationships.
c) Use Banker Almanac tool or any approved directory to spool KYC for clients wishing to set Relationship Management for correspondent banking relationship.
d) In liaison with business units, conduct annual review of our correspondent banking relationships with regard to Anti-Money Laundering (AML) and Know Your Customer (KYC) practices and procedures
e) AML/CFT query management for our correspondent banking relationship.
8. Reporting and record keeping entailing:
a) Timely submission of:
- Risk and Conduct Committee report
- Executive Committee Reports
- Managing Director’s Report
- Monthly compliance report for South Africa compliance
- Country Risk Report
- Key Risk Indicators
- Quarterly Board Risk and Technology Committee reports
- Quarterly Board Audit Committee reports
b) Maintenance of records related to AML/ CFT duties specified above including training records, supporting documents used to resolve alerts.
c) Ensure timely submission of regulatory reports to the regulatory authorities which include the Financial Reporting Centre, Central Bank of Kenya.
Preferred Qualification and Experience
• Undergraduate degree in business;
• Professional course in Money Laundering eg Certified Anti-Money Laundering Specialist (CAMS), International Compliance association (ICA) and equivalent.
• Minimum 5 years of experience in the AML/ CFT and Compliance in the banking industry;
Knowledge/Technical Skills/Expertise
• IT skills in data analytics is an added advantage.
• AML knowledge in insurance industry is also an added advantage.
• Comprehensive understanding of the regulatory and business environment of the banking industry.
• Understanding of business unit needs and ability to translate them into risk management solutions.
• On-going awareness of regulatory requirements related to banking industry.
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