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Job Purpose
FC Investigations function has been formed to create an industry leading capability within the bank to investigate cases pertaining to all types of Financial Crime Risk. The investigators will investigate the cases that are classified as ‘Major Cases’.The investigators will work mostly the cases related to fraud, both external and internal fraud. The investigators will also handle cases related to other financial crime risks such as AML, AB & C, Terror Finance subject to allocation. Fraud Risk impacts the bank both reputationally and financially and hence the investigators will also work on filing police complaints and follow up on court matters on account of such cases. The role holders will be based out of multiple locations across country and will be sole point of contact for FC Investigations locally.
Role holders will carry out activities that will include most of the following:
1.To manage fraud investigation function in the areas of secured and unsecured lending, primarily related to the WPB business, within the framework of policies issued by the Group & INM and under the overall guidance provided by SVP FC Investigations.
This will include compliance with appropriate Investigation guidelines/procedures relevant to secured/unsecured lending, liaison and conduct regular audit of the Areas to ensure all the angles of Financial Crime is investigated, reported and to strengthen rapport with the law enforcement agencies.
Principal Accountabilities: key activities and decision-making areas
Impact on the Business/Function
·Ensure timely instructions are given to the application processing team to stop processing of identified fraudulent applications.
·Identification of set-up companies/body of individuals to prevent future sourcing from these companies by ensuring accurate & timely investigation of all suspect cases referred by Instinct Team as per the agreed TATs and procedures bearing in mind the latest fraud trends
·Prevent and minimize fraud exposure/losses on account of fraudulent applications by identifying gaps in verification/application processing workflows and recommend corrective measures, wherever necessary.
·MI and other business data requirements are completed accurately and supporting statistics/reports/returns are presented to business/management within agreed timescales.
·Ensure that the investigations are conducted as per Internal guidelines. Internal (staff fraud / accountability) cases are conducted in the most dignified manner.
·To represent the bank as ‘Power of Attorney’ holder in filing criminal cases by the bank. Ensure proper information sharing and follow up with law enforcement authorities related to these cases.
·Support RBB, CMB lending, GTRF related referrals as part of CMB fraud ops/ Tradnet alerts, FC-UAR
Customer / Stakeholders
Largely touches the WPB, HR, SD and CMB and GTRF businesses / functions.
·Establish and maintain effective relationship with customer business areas and identify areas of service improvements.
·Maintain good liaison with local law enforcement adhering to internal Ab& C guidelines.
·Maintain a close relationship with counterparts in peer banks to be abreast with the prevailing fraud trends.
·Conduct local fraud awareness trainings for Bank staff / third party sales staff.
Surprise checks at third party sales agents appointed by business.
Leadership and Teamwork
·Build collaborative relationships and demonstrate HSBC values.
·To be an effective back up for each other within FC Investigations
·Closely coordinate with relevant stakeholders namely Service delivery, Credit Risk, CCS, WPB sales teams, HR.
Operational Effectiveness & Control:
·Ensure timely investigation of the case with proper feedback and logical conclusion on fraud cases.
·Ensure timely and qualitative investigation on fraud case and submit detailed fact finding (investigation) report.
Management of Risk
The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organization.
This will be achieved by consistently displaying the behaviors that form part of the HSBC Values and culture and adhering to HSBC risk policies and procedures, including notification and escalation of any concerns and taking required action in relation to points raised by audit and/or external regulators.
The jobholder is responsible for managing and mitigating operational risks in their day to day operations. In executing these responsibilities, the Group has adopted risk management and internal control structure referred to as the ‘Three Lines of Defence’.
The jobholder should ensure they understand their position within the Three Lines of Defence, and act accordingly in line with operational risk policy, escalating in a timely manner where they are unsure of actions required.
Through the implementation the Global AML, Sanctions and ABC Policies, supporting Guidance, and Line of Business Procedures the jobholder will make informed decisions in accordance with the core principles of HSBC's Financial Crime Compliance Risk Appetite.
Observation of Internal Controls
The jobholder will adhere to, and be able to demonstrate adherence to, internal controls and will implement the Group compliance policy by adhering to all relevant processes/procedures.
The term ‘compliance’ embraces all relevant financial services laws, rules and codes with which the business has to comply.
This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators.
Local Job Requirements
Major Challenges
The jobholder is expected to display maturity, and a sense of judgment in decision-making There are no set guidelines within which the incumbent can follow to detect fraud and to that extent the job is extremely challenging. It involves thinking out of the box, as the jobholder needs to be a step ahead of the fraudster. The jobholder contributes and receives guidance from the SVP– FC Investigation & other stakeholders within Compliance.
Given the extreme sensitivity of the job, apart from being vigilant and alert at all times, the job holder needs to keep himself/herself constantly updated with regards to the prevailing fraud practices (local and international) by means of alerts, observations etc is vital. Being in constant interaction with competitors and exchanging critical information is again very essential, as this would help stem potential fraud exposure.
In the industry, most banks, NBFC rely on separate specialist staff depending on product, such as Mortgage fraud risk, Secured lending, Unsecured lending, SME/ wholesale / agree lending, staff / internal case investigators (insider risk), AML investigators etc. Also across industry such roles are also supported/ lead by Regional / Zonal Fraud risk managers. However, within HSBC, the jobholders will be expected to deliver as SME in investigations for all type retail /. Commercial loan products and also for internal case. They will be solely managing the location/ region.
Role Context
·Fraud risk function has evolved in banking sector in India. The fraud syndicates are now organized and have started defrauding banks.The challenge continues to maintain the Frauds and credit related operational losses faced by banks due to weak KYC documentation & transaction (s) fraud or failure to spot early tread which has a direct impact on the banks profitability.Large scale bank fraud has surfaced in last 2-3 years especially in Digital and Corporate area, impacting the bank significantly. Whilst fraud prevention is the key, investigation, police / court cases, ensures fraud recovery and deterrence and contain reputational damage.
·Severe impact like increased losses on account of fraudulent application & transaction frauds can hava cascading effect on the WPB business strategy and growth, including reputation risk.
Job Dimensions:
The role holder will be placed in key locations (mostly metros) across India and will be the sole FC Investigation contact for the location (Nearby branches).
Typically, every role holder will be responsible to manage Investigation of Financial Crime.Typically, yearly the role holder would investigate more than 100 Major cases for investigation and few police complaints to file locally