FinancialCrime Compliance (FCC) is a sub-function of the Financial Crime Risk (FCR)function. The purpose of the FCC sub-function is to execute second-lineresponsibilities with regards to financial crime risk. It achieves this by:Setting risk appettite and writing policy; providing advice on financial crimerisk matters to the first line of defence; and providing oversight over financialcrime risks.
The FCC Risk Strategy Manager a key riskmanagement, oversight and reporting role that has a broad remit,responsibilities and accountability for ensuring adequate controls are in placeto manage financial crime risk of the Lines of Business and Functions.
Principalrole and responsibilities include:
FCC Risk Appetite Statement (RAS)
Coordination of commentary for FCC RAS reporting
Support and oversight of LOB FCC RAS reporting
Managing FCC RAS governance (Year-end and Mid-year Refresh)
Providing training on FCC RAS metrics and usage
Conducting Annual FCC RAS assurance on countries
Enterprise Risk Reporting: Top & Emerging(T&E) Risks, Risk Map
Coordination of Top & Emerging Risks and Risk Map inputs for RMM and FCRMC reporting
Training to FCR stakeholders on T&E and Risk Map
FCR MI Dashboard
Oversight, Coordination and
Monitoring of Risk Assessment processes and Operational Risk ManagementFramework (ORMF)
Executionof annual Anti-Money Laundering (AML) and Sanctions Enterprise Wide RiskAssessment (EWRA process
Executionof critical targeted risk assessments triggered by Management, Regulatory ormaterial trigger events.
Oversightof 1LoD RCAs.
Input to CEO Scorecards
Coordination of FCR Horizon Scanning, a keyactivity that promotes awareness and trend analysis of material events andregulatory development that may impact business and functions.
Coordination of FCC review of Group StandardsManual (GSM) applications, a core governance discipline for the HSBC
Group and the US, designed to enable all relevantstakeholders to review transactions relating to changes to the Group structureprior to their execution.
The role requires strong partnership with the LOBs,Financial Crime Risk sub-functions, HOST and other functions at country andglobal levels to meet the recurring country and Group internal and regulatory reportingrequirements, ensuring established deadlines are met, and the deliverables arewithin scope.
Impacton the Business
Develop and maintain US capability to provide the US Head ofFCC / Bank Secrecy Compliance Officer with insightful analysis andprioritisation of relevant information to inform the opinion as the FCC Risksteward.
Develop and implement best practice standards, and proceduresto govern the execution of Risk Analysis in Region.
Provide direction and support to teams that provide FCCoversight and reporting capability in region to achieve a consistent quality ofanalysis.
Work in collaboration with the FCC LoB teams and regional LOBteams to agree and establish a single view of the effectiveness of the thefinancial crime control framework that can be communicated consistently tosenior first line management.
Maintain the documents of record of the FCC Risk Stewardrelevant to the performance of risk analysis.
Own and maitain the the Risk Appetite, Risk Appetite Metricsand Risk Taxonomy for AML, ABC and
Sanctions risks, keepig them relevant and current.
Suppor the development and delivery of the Enterprise WideRisk Assessment (EWRA) to be an effective tool to manage risk and deliver theEWRA report to time and quality.
Ensure that information is shared cross geography andbusiness on relevent financial crime risk issues.
Coordination of FCR Horizon Scanning, a key activity thatpromotes awareness and trend analysis of material events and regulatorydevelopment that may impact business and functions.
Coordination of FCC review of GSMs.
Coordinate input from FCR in relation to CEO achievement ofFCR-related Scorecard measures
Support the US Head of FCC / Bank Secrecy Compliance Officer in identifyingrisk issues in their areas of responsibiliy.
Regular review of Key Risk Indicators (KRIs) and KeyPerformance Indicators (KPIs) to oversee the effective financial crime riskmanagement for the LOB(s) supported.
Act as champion for Operational Risk-related matters.
Build constructive relationships with Global Internal Audit, Financial Crime Riskstakeholders to produce an aligned view of risks between second and third lineof defence.
Ensure the US Head ofFCC / Bank Secrecy Compliance Officer isappropriately advised of material FCC issues across the Region.
Work closely with the Financial Crime and Threats Mitigation(FCTM) Unit to manage Risk and Compliance matters.
Support the FCC LOB Advisory teams to provide timely andaccurate advice to the business.
Develop and communicate a powerful and compelling vision thatinspires and engages people with the HSBC Values and goals as the basis of aninclusive, high performance, customer-centred culture.
Lead, develop and motivate team to attract, retain and developthe capacity, capability and talent to provide for succession and ensuredelivery of business objectives.
Set expectations, share best practice and manage, monitor,coach and develop leaders and managers to ensure that they maximise theirperformance, meet the required standards, and continuously develop theircapabilities and experience.
Drive and encourage constructive cross-country andcross-business teamwork by demonstrating collaboration and matrix management inaction and taking prompt action to address any activities and behaviours thatare not consistent with HSBC's diversity policy and/or the best interests ofthe business and its customers.
OperationalEffectiveness & Control
Financial Crime Compliance operating model to ensure the business operatesincreasingly effectively and efficiently and is able to deliver HSBC'sstrategic goals.
Establish and maintain a robust and efficient controlenvironment across Financial Crime Compliance to ensure good operational,financial and project management and compliance with HSBC policy andprocedures, together with early identification and effective resolution ofissues that arise.
Lead the development, implementation and maintenance of a regionalmanagement information, analysis and reporting framework that supports andinforms timely and effective business management and decision making at alllevels.
Drive the definition and embedding of policy and governanceframeworks across Financial Crime Compliance to ensure quality, effective riskmanagement and regulatory compliance.
Complete other responsibilities, as assigned.
The jobholder will ensure the fair treatment of our customersis at the heart of everything we do, both personally and as an organisation.
This will be achieved by consistently displaying thebehaviours that form part of the HSBC Values and culture and adhering to HSBCrisk policies and procedures, including notification and escalation of anyconcerns and taking required action in relation to points raised by auditand/or external regulators.
The jobholder is responsible for managing and mitigatingoperational risks in their day to day operations. In executing theseresponsibilities, the Group has adopted risk management and internal controlstructure referred to as the 'Three Lines of Defence'. The jobholder shouldensure they understand their position within the Three Lines of Defence, andact accordingly in line with operational risk policy, escalating in a timelymanner where they are unsure of actions required.
Through the implementation the Global AML, Sanctions and ABCPolicies, supporting Guidance, and Line of Business Procedures the jobholderwill make informed decisions in accordance with the core principles of HSBC'sFinancial Crime Risk Appetite.
The jobholder has responsibility for overseeing and ensuringthat Operational risks are managed in accordance with the Group StandardsManual, Risk FIM, & relevant guidelines & standards. The jobholder should comply with the detailedexpectations and responsibilities for their core role in operational riskmanagement through ensuring all actions take account of operational risks, andthrough using the Operational Risk Management Framework appropriately to managethose risks.
This will be achieved by:
Continuously reassessing risks associated with the role andinherent in the business, taking account of changing economic or marketconditions, legal and regulatory requirements, operating procedures andpractices, management restructurings, and the impact of new technology.
Ensuring all actions take account of the likelihood ofoperational risk occurring, addressing areas of concern in conjunction with
Risk and relevant line colleagues, and also by ensuring that actions resultingfrom points raised by internal or external audits, and external regulators, arecorrectly implemented in a timely fashion.
Observationof Internal Controls
The jobholder will adhere to, and be able todemonstrate adherence to, internal controls and will implement the Groupcompliance policy by adhering to all relevant processes/procedures. The term'compliance' embraces all relevant financial services laws, rules and codeswith which the business has to comply. This will be achieved by adherence toall relevant procedures, keeping appropriate records and, where appropriate, bythe timely implementation of internal and external audit points, includingissues raised by external regulators.
The following statement is only for roles withmanagerial or specific Compliance responsibilities.
The jobholder will implement measures to containcompliance risk across the business area. This will be achieved by liaising with
Compliance department about business initiatives at the earliest opportunity.Also and when applicable, by ensuring adequate resources are in place andtraining is provided, fostering a compliance culture and optimising relationswith regulators.
Experienced professional within the financial services industry.
Significant experience in financial crime compliance, operational and/or project management roles.
Extensive knowledge of FCC regulations and guidance preferred.
Understanding of the HSBC Group structure and its corporate culture preferred.
Lateral thinker with an ability to interpret and solve complex issues.
Proven/Excellent leadership skills/ability to matrix manage.
Excellent communicator with strong inter-personal skills.
Demonstrate ability to lead change, contributing to joining up with the other teams in Risk and Business Regionally
Ability to organise/prioritise effectively.