Financial Crime Risk Officer - International Banking Unit (GIFT City)

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COMPLIANCE

The Compliance function is a Second line of defence (LOD) function, responsible for reviewing and challenging the activities of the Group’s businesses (also referred to as “the First LOD”) to ensure that they effectively manage as “Risk Owners” the Regulatory and Financial Crime Compliance risks inherent in or arising from the conduct of their activities and for which they are responsible. The Second LOD consists of 'Risk Stewards' who are independent of the commercial risk-taking activities undertaken by the First LOD. The Compliance function is a Risk Steward for a number of non-financial risks in accordance with HSBC Group’s risk framework.

The Financial Crime team comprises risk specialists across money laundering, fraud, sanctions, tax transparency, bribery and corruption and terrorist financing; advisors who review and challenge business capabilities and strategies; and investigation and detection teams using data, technology and operating processes to manage our financial crime risk. The Financial Crime team also sets policy and framework, promotes consistent implementation and best practice, and provides effective oversight on the HSBC Group’s businesses to ensure that the Group’s exposure to financial crime and related reputational risk is well-managed.

The Financial Crime Risk Officer for HSBC International Banking unit, Gift City (HIBU) is an accountable executive responsible and supporting the Compliance officer –HIBU and Head of Financial Crime Risk- India in ensuring that HSBC’s operations in IBU are effective in identifying, managing and mitigating Regulatory Compliance and Financial Crime risks and ensure timely advice is provided to the business.

Responsibilities :

• The Financial Crime risk Officer is responsible for ensuring that HSBC's operations in Gift City are effective in identifying, managing and mitigating Financial Crime risks and ensure timely advisory is provided to the business. Primarily focus on exercising FC risk stewardshipand supporting Compliance Officer, HIBU to maintain an effective control framework and to ensure compliance with all relevant external laws & regulations, internal codes and policies and good market practices. The role holder is responsible for 1.    Provide advisory services in order to ensure clear understanding of financial crime risk exposure with respect to clients, transactions and products.2.     Articulate the Financial Crime risks for International Banking unit, Gift City India3.    Be responsible for second line governance of Financial Crime risks exposures, providing analysis, reporting and governance to HIBU that is independent of the first line of defence, thereby maintaining an objective assessment of risk exposure. 4.    To exercise risk steward challenge, act as independent trusted advisory in governance forums, issue management, fostering a compliance culture and optimizing relations with risk owners and control owners. Advise, review and challenge 1st LOD on the identification, impact assessment, resolution and investigation of material internal risk events including near misses relating to their risk type5.    Provide policy oversight, challenging and guiding Risk and Control Owners to support implementation and adherence to Financial Crime related policies and regulations.6.    Assist senior management of HIBU, leadership of the Compliance function, and other colleagues on all material financial crime risk related matters. 7.    Provide insights from the external environment, oversight, challenge, and escalation at key risk governance forums and contribute to wider operational risk governance.
• 8.   Act as principal point of contact for internal and external stakeholders in relation to Regulatory matters / Transaction Monitoring/Investigation risk.
• 9.   Act as a Principal officer for Anti Money Laundering (AML) related matters for regulatory authorities

Principal Accountabilities

The following principal accountabilities are aligned to the Compliance Services and Processes Model. Additional detail is available in the Model.

Impact on the Business

·Support in overseeing the critical FCR policies and systems that impact HIBU, Gift City India and ensure that the Group’s exposure to Financial Crime risks is managed in a commercially sensitive, practical and cost effective manner.

·Provide advice and support on Financial Crime risks to senior management, Compliance and other colleagues.

Stakeholders

·Reporting to Compliance Office and to the INM Head of Financial Crime Risk as relevant on Regulatory Compliance and Financial Crime risks matters.  

·Ensure that senior management are appropriately advised of all material Compliance related matters relating to the International Banking unit, Gift City India  

·Manage and foster a strong relationship with all relevant regulators in relation to the activities of the International Banking unit, Gift City India and ensure timely disclosure of relevant information, in relation to financial crime compliance related matters.

·Ensure that positive relationships are maintained with other external stakeholders relevant to the Compliance agenda.

Leadership and Teamwork

·Maintain and develop positive and professional working relationships with senior business managers and Compliance colleagues at the Group level and those in other Regions and Businesses.

·Support Head GIFT City, Compliance Officer and the INM Head of Financial Crime Risk in creating an environment for the delivery of consistent performance measurement, training, career management and succession planning across the Compliance capability.

·Support Head GIFT City, Compliance Officer and the INM Head of Financial Crime Risk in establishing a strategy for the sharing of Financial Crime risks related compliance knowledge and best practice across the wider Compliance Function and Group.

Operational Effectiveness and Control

·Create a framework for the effective risk-based monitoring of the implementation of Financial Crime risks related policies and controls across International Banking unit, Gift City India.

·Agree and oversee the implementation, embedding and monitoring of the adherence to the Compliance FIM in International Banking unit, Gift City India.

·Monitor and assess the resourcing, costs and spend of the International Banking unit, Gift City India Compliance Function. 

Management of Risk

·This will be achieved by ensuring all actions take account of the likelihood of Compliance risk occurring and by addressing any areas of concern in conjunction with line management and/or the appropriate department.

Observation of Internal Controls

·Managers are accountable for setting the ‘tone at the top’ which underpins the principles of a positive and effective internal control environment.  They should exhibit leadership and direction to their teams for establishing and maintaining an effective internal control environment, including the development and management of policies and procedures where appropriate. 

·Managers should also ensure that suitable processes are put in place to review and oversee that internal control environment against those policies.

Local Job Requirements

• Major Challenges
• HSBC is an extremely diverse business with significant geographical spread and activities that span a universal banking model, including continuing to innovate to keep abreast of changes in financial services markets globally.  Such activity is in an increasingly regulated and complex global environment with often little consistency between laws and regulations in different jurisdictions and regulators taking a far more proactive approach in ensuring local compliance with their requirements and imposing increasingly stringent sanctions for breaches.   It is the role of the Financial Crime Risk Officer- GIFT City International Banking Unit, India , as a member of the Compliance function to assist the Group in achieving a balance between the demands of regulators, external bodies and governmental initiatives and the Group’s shareholders and customers in enacting compliance; being alive to the political, management, regulatory and reputational implications of a particular decision and courses of action at a global level; assisting executive management in the development of controls and systems and influencing the way in which the business is conducted in order to manage these risks, meeting Group risk appetite.  The increased focus on individual liability for senior managers, particularly risk heads, makes it increasingly important for the Group to be able to evidence adequate systems and controls.  The role is one where regulatory authorities have high expectations and is likely to come under scrutiny as part of any major regulatory investigation.