Strategy (Responsibilities that are related to the development and implementation of a financial crime strategy)

• Input to Country operating model design of relevant FCC and business processes.
• Ensure that there is adequate support (people, processes, tools, frameworks, systems) in the Country for necessary FCC controls.
• Set and implement the vision, strategy, direction and leadership for the Country, consistent with the vision and strategy for FCC and in support of the Group's strategic direction and growth aspirations.

Business (Responsibilities related to the delivery of business and/or financial objectives)

• Analyse comprehensive impact of financial crime related regulatory matters on the relevants business area and its operations.
• Ensure that key changes (to laws, rules, regulations) are communicated and cascaded in country, in coordination with group communications.
• Support relevant stakeholders to make decisions based on current and possible future policies, practices, and trends.
• Keep track of and provide advice to relevant stakeholders on the interpretation and application of regulatory expectations, laws, best practices and policies related to FCC.
• Support resolution of competing requirements between regulations, for example between AML regulations and data privacy/bank secrecy, or information security regulations.

Processes (Processes for which the role is responsible under the ORF as 1st & 2nd line; for executing/ completing, and for supervising)

• Develop, keep up to date and recommend for approval by the relevant Risk Committee, appropriate policies/processes/DOI's to address financial crime risks, aligning with relevant regulatory requirements.
• Providing governance and oversight over the implementation of FCC related policies and procedures in Country to ensure compliance with such policies and procedures.
• Act as Process Owner for FCC owned (sub-) processes under the Group's Enterprise Risk Management Framework, including implementation and roll-out of relevant processes and DOI's.
• Provide advice to relevant stakeholders on compliance with Group standards relating to FCC, namely AML and Sanctions.
• Act as (second line) Risk Control Owner under the Group's Enterprise Risk Management Framework for those aspects of Regulatory Compliance relating to AML and Sanctions and escalate issues as appropriate.

People and Talent (Responsibilities related to people and talent retention matters)

• Provide leadership, management and coaching to direct reports to ensure they are highly engaged and performing to their potential.
• Promote and embed a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm.
• Stimulate an environment where forward planning, prioritisation, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm.
• Provide input at business, function, country and individual level as appropriate, on compliance matters which should have a bearing on remuneration pools or individual bonuses (for senior staff).
• Collaborate with training teams to input to training curriculum to support closing of capability gaps.
• Ensure Country is adequately resourced and staffed by an appropriate number of competent staff sufficiently independent to perform duties objectively, to support sustainable business growth and address financial crime risks.
• Ensure staff in Country have clearly articulated and well understood roles and responsibilities through meaningful and accurate job descriptions.

Risk Management (Responsibilities under Enterprise Risk Management Framework – both execution and supervisory under AML & Sanctions)

• Maintain oversight of risk mitigating action plans.
• Establish and maintain watch lists used for customer and transaction screening and various other due diligence and investigative purposes (local/regional, internal and external).
• Provide advice on the application of risk management frameworks (e.g., ORF, GRA), especially in line with the Financial Crime Risk Type Framework under the Enterprise Risk Management Framework.
• Apply Group and FCC policies and processes (AML surveillance, client screening, risk assessment) to manage risks.
• Make recommendations (and/or implement) to relevant stakeholders on possible risk management responses to identified risks and/or findings of concern from investigations.
• Assess risks arising from products / segments / geographies / customers / transactions.
• Inform senior management, country risk committees and relevant regulators of serious regulatory breaches (or where risk tolerances have been breached) and ensure that actions are taken quickly to remediate and/or activities are ceased.
• Anticipate horizon risks in financial crime that may have a significant impact on the Group and develop effective strategies to mitigate such horizon risks.
• Conduct country risk assessment.
• Advise relevant stakeholders on outcomes of AML and Sanctions risk identification and assessment methodologies, and the performance of gap analyses as appropriate.
• Deliver/ support delivery of delivery of annual Group AML and Sanctions Risk Assessments.
• Partner with legal counsels for advice on technical matters.
• Oversee the review and analysis of the client base to identify and manage high risk clients, or specific country reviews.

Anti-Bribery and Corruption (delivering an effective Anti-Bribery and Corruption program as Country ABC Lead)

• Oversee and monitor the implementation of the Group ABC Policy and Procedures in-country, including documenting any gaps between Group standards to local regulatory and legal requirements.
• Communicate Group ABC Policy and Procedures to staff; lessons learned from Enforcement Actions; or any other ABC related programme communications.
• Support the undertaking of the ABC Group Risk Assessment and to develop corrective action plans for self-identified ABC issues and report to the relevant country risk committee.
• Ensure all relevant staff in country are trained in the requirements of the ABC Policy and Procedures and that training is updated as required by developments and changes in local law and regulation related to ABC.
• Provide oversight and monitoring of country-level ABC audit and assurance findings and progress of treatment plans.
• Execute roles and responsibilities as applicable in relevant ABC controls.
• Review Country ABC MI reports received from the ABC Centre of Excellence team and analyse the information to identify trends and develop commentary for presentation at CFCRC or other relevant country governance forum.
• Escalation of ABC operational and programme risks and issues to in-country forums and to the ABC Centre of Excellence team, as appropriate.
• Manage oversight of the ABC Operational Risk Framework in country with assessments of Residual Risk Ratings as RO Delegate (at country level) with the Country PO and OR representatives, covering respective ABC focus areas,
• Maintain regular stakeholder engagement with segments and functions relevant to ABC in country.
• Seek opportunities to champion the ABC agenda, both internally and externally to the Bank.

Governance

• Attend relevant leadership meetings.
• Provide senior oversight of FCC country.
• Ensure tracking and remediation of surveillance and investigations related regulatory findings.
• In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure senior management and relevant regulators are informed and that actions are taken quickly to remediate and/or activities are ceased.
• Prepare and cascade lessons learned from audit findings, FCC assurance activities and specific investigations.
• Provide leadership to the FCC network as part of the Group senior FCC management team.
• Track significant issues arising from FCC metrics, FCC Assurance activities, Audit reviews and regulatory inspections, providing validation of issue closure where necessary.
• Propose control improvements, enhancements and simplifications where appropriate.
• Be accountable for identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework.
• Collate, analyse and interpret data in reports to senior management and relevant governance/risk committees.
• Analyse and interpret data to produce reports that help the bank identify and manage emerging areas of risk / vulnerability and thus drive remediation action within the FCC function.

Project/Change Management

• Act as accountable executive for key change programmes.
• Lead or influence significant programmes of work in support of the financial crime compliance objectives.
• Provide skilled resources to support project/programme delivery.
• Manage and protect business as usual (BAU) capability during change programmes, as well as during the execution and delivery of the Remediation initiatives through project phase and into BAU.

Regulatory & Business Conduct

• Display exemplary conduct and live by the Group's Values and Code of Conduct.
• Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct, across Standard Chartered Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.
• Lead the country to achieve the outcomes set out in the Bank's Conduct Principles: Fair Outcomes for Clients; Effective Operation of Financial Markets; Financial Crime Prevention; and The Right Environment.
• Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.
• Manage as a single reference point within the organization to whom all employees and officers are instructed to promptly refer all transactions suspected of being related to money laundering or terrorism financing, for possible further reporting via Suspicious Activity Report to the Anti-Money Laundering Office.
• Manage regulatory interaction on FCC issues with the bank's regulators, including the Bank of Thailand, and the Anti-Money Laundering Office.
• Represent the bank through relationships with local banking associations and groups.
• Raise the profile of the bank through outreach.
• Support relevant stakeholders to respond to any regulatory questions.

Key Stakeholders

• Country CEO
• Country Compliance
• Country Business Heads
• Country Chief Risk Officer
• Country Audit
• Country Legal
• Country Business Operational Risk
• Country Business Operations
• Financial Crime Surveillance Unit (FCSU), Global Business Services located in India & Malaysia
• Regional Heads of FCC
• Local Regulators
• Local Financial Intelligence Unit and law enforcement agencies
• Local banking associations
• Peers in other banks/industry

Other Responsibilities

• Embed "Here for good" and the Group's brand and values in country.
• Demonstrate exemplary integrity, ethics and values.
• Perform other responsibilities assigned under Group, Country, Business or Functional policies and procedures.
• Manage usage of surveillance services provided by the Financial Crime Surveillance Unit, including service level agreement and maintaining general liaison with the FCSU hubs.
• Manage and oversee any FCC related matters for the Representative Offices of the three Greater Mekong Sub-Region countries of Cambodia, Laos, & Myanmar, maintaining general liaison with the GMS Chief Representatives.
• Manage the Secretariat for the Country Financial Crime Risk Committee (CFCRC - Thailand & GMS).
• Perform Money Laundering Reporting Officer (MLRO) duties as Country Money Laundering Compliance Officer (CMLCO), under delegation of the Country Head of Compliance.

Our Ideal Candidate