Details of the Division and Team:
Regulations, Compliance and Anti Financial Crime (AFC) protect the integrity and reputation of Deutsche Bank. They manage the bank’s risk and help to avoid unintentional rule breaches and conflicts of interest.
At the same time, they also advise on ethical conduct, governance issues and keep our organisation up to date on regulatory and political challenges.
Anti Financial Crime at Deutsche Bank is committed to the highest standards of Anti-Money Laundering (AML), Combatting Terrorist Financing, Sanctions & Embargoes, Anti-Bribery and Corruption (ABC) and Fraud prevention.
The Management and all employees are required to adhere to these standards to prevent DB and our reputation from those who may intend to use our products and services for money laundering, bribery, corruption, fraud and/or Terrorist Financing (TF) purposes.
DB Group will examine its Anti-Financial Crime (AFC) strategies, goals and objectives on an ongoing basis and maintain an effective program for DB’s business that reflects the best practices for a diversified, global financial services provider.
Role Overview :
The AFCO Function is responsible for the AML, CTF, Sanctions & Embargoes, Anti-Commercial Concealment, Anti-Fraud & Investigations (AFI), ABC activities in the jurisdiction. Where ABC or AFI headcount is not present in the location, the responsibility is delegated to the respective regional team (such as Saudi Arabia). This ensures that all relevant AFC policies, procedures, systems and controls are implemented effectively, all AFC-relevant legal, regulatory (Saudi AML Law and SAMA AML/CTF Rules) and DB Group requirements are met and any AFC-related risks are appropriately addressed and mitigated.
The AFCO is also responsible for the identification, assessment, advice on, monitoring, control and reporting on the AFC laws, rules and standards relevant to the DB activities in their respective jurisdiction,
The AFCO is the direct point of contact for DB staff in AFC matters, in particular in terms of whistle-blowing, employee reliability or concerns raised in a confidential environment when improper or illegal AFC related activities are suspected,
Identify, assess, advise, monitor and report on the regulatory and compliance risks for their assigned Deutsche Bank country branch
Manage the Bank’s regulatory and compliance risks, and develop and maintain an appropriate internal control framework
Protect Deutsche Bank against Compliance risks which may include client detriment, regulatory sanctions, financial loss and reputational damage and advise staff across the Bank on ethical conduct, and external regulatory challenges
Manage country regulatory relationships ensuring appropriate support and escalation
Partner with the business in understanding and managing related risks and controls.
Deutsche bank Africa and Middle East
Deutsche Bank’s commitment in the MEA region is more than a century old , beginning with the Bank’s Financing of the constitution of the Bagdad railway.
Deutsche Bank AG in the MEA region offers the full range of Investment Banking, Asset Management , Private Wealth Management and Global Transaction Banking services. Deutsche Bank AG is well recognized for its leading role on some of the most prestigious regional transactions. The bank is recipient of the several regional and international awards in recognition for its achievements in Investment Banking and Islamic finance in the region.
The Global focus of Deutsche Bank’s social responsibility is reflected in its regional unit and foundations. Hence the decision to establish Deutsche Bank’s Middle East stemmed from Deutsche Bank’s deep-seated belief in the necessity of companies contributing to the societies in which they operate.
Established in 2008, Deutsche Bank’s middle east foundation is one of the Bank’s many foundations around the Globe across Asia, Africa, Europe and the Americas. Deutsche Bank’s middle East Foundation focuses on funding investments in Arts, Education, Community Development, Sustainability and volunteering in the Middle East and North Africa Region.
What we will offer you:
A healthy, engaged and well-supported workforce is better equipped to do their best work and, more importantly, enjoy their lives inside and outside the workplace. That’s why we are committed to providing an environment with your development and wellbeing at its center.
You can expect:
Life Insurance
Accidental Death Insurance
Permanent Partial Disability Insurance
Private Medical Insurance
Flexible working arrangements
30 days of annual paid leave, plus public holiday & Flexible Working Arrangement
Your key responsibilities:
Support senior management and employees of Deutsche Bank in understanding and managing:
the application of Deutsche Bank’s ethical standards and professional principles
general compliance with the relevant laws, rules, regulations, directives and DB Group standards across the activities and business operating model of the assigned country, that fall under the Compliance risk types
the prevention and escalation of issues, incidents and breaches relating to Compliance
the implementation of processes and procedures regarding abuse of assets, systems, information or procedures, for example those involving Confidential Information and Price Sensitive Information (PSI)
cross-border compliance related matters.
Ensure implementation and maintenance of adequate policies and procedures with clarity of accountability and ownership across the first and second lines of defence; ensure such documents support the local country requirements, local management and staff in complying with all related legal and regulatory obligations, relevant Deutsche Bank Group standards as well as best practices and integrity standards applicable to their activities.
Report regularly to the relevant Deutsche Bank Country Operating Committee, branch Compliance Committee, where necessary, Regulatory Authorities (SAMA) on Compliance matters, amongst others, indicating whether:
any significant risk exposures and material incidents of non-compliance have been identified
appropriate measures have been taken to address any gaps or deficiencies
the Compliance frameworks (structure and processes) are adequate, effective and in line with legal, regulatory and Deutsche Bank Group requirements.
Undertake and be actively involved in proactive and reactive management and escalation of all Compliance risks, issues and breaches, for example, conducting risk assessments.
Monitor and test compliance with laws, rules, regulations and internal controls in accordance with agreed policy and methodology; report and manage any findings or issues, and support management in their identification of appropriate remedial action plans.
Participate in, and provide compliance support to, relevant projects ensuring adherence to related standards, mitigation of associated risks and strong stakeholder consideration particularly focussed on the client or customer.
Liaise with Compliance senior management within DB Group to ensure appropriate reporting and escalation of issues and/or incidents.
Provide compliance advice regarding development of new products in line with appropriate processes and procedures; ensure clear demarcation of such advice from that of other control functions.
Support a compliance aware culture within the assigned country, including regular and appropriate local education, training and awareness by leveraging related global initiatives.
Participate in local and global Compliance projects instigated by Deutsche Bank Group.
Act as a direct contact point for Deutsche Bank country staff to confidentially raise concerns in relation to compliance matters or when improper or illegal activities are suspected (e.g. conflicts of interest, money laundering, market abuse etc.)
Provide local and regional support to the Regional and Global Compliance management teams, as and when required.
Act as a contact point for SAMA, represent DB Riyadh in various of regulatory committees along with other banks in Saudi Arabia.
Anti-Commercial Concealment:
Compliance Locally must assume and promote the responsibility for Anti-Commercial Concealment in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional ABC teams.
In those locations where the CO has dedicated Anti-Commercial Concealment headcount, local Anti-Commercial Concealment will undertake certain Anti-Commercial Concealment tasks locally in relation to these responsibilities, as appropriate (based on resource level and capability in relation to the issue in question) and as determined by the relevant Regional Head of Compliance.
In Saudi Arabia where the CO has no dedicated Anti-Commercial Concealment headcount, the CO must refer all Anti-Commercial Concealment matters to the relevant Regional Head of Compliance who will provide support in delivery against these Anti-Commercial Concealment responsibilities remotely from a regional level. (Banking Secrecy applied).
The AFCO has decision-making authority over the Business on AFC related matters.
The AFCO has unrestricted access to all information, data, records and systems in the Bank he/she deems necessary to fulfil its function.
Advising on and ensuring implementation of AFC policies and procedures whereas involvement in ABC and AFI policies depends on the availability of headcount in the location and if none, this will be assisted by the respective regional team.
Advising on the impact of new AFC related internal and external rules and ensuring that local guidelines and procedures are in line and reflect German and Saudi laws / regulations. Escalate exceptions to the Regional Head of AFC (Banking Secrecy applied).
Assessing the conformity of internal policies and procedures, systems and controls with relevant regulatory obligations and DB Group standards.
Being primary point of contact for AFC matters with competent regulatory, law enforcement or other public authorities in Saudi Arabia, and in the absence of local ABC and AFI headcount, in conjunction with the respective regional heads (Banking Secrecy applied).
Reporting and liaising with Regional Head of AFC and other AFC Senior Management to ensure appropriate reporting and escalation of issues and/or incidents (Banking Secrecy applied).
Contributing to DB AFC Function as a whole by sharing knowledge and best practices with AFC Officers of the other Businesses and entities and other AFCOs. Contribute to the development of AFC methodologies by cooperating with other disciplines like Compliance, Legal, Audit and Operational Risk Management.
Ensuring timely delivery of the local AFC Risk Assessment in the country leveraging off regional assessments performed for ABC and AFI topics.
Providing AFC advice in the change management process including but not limited to the New Product Approval (NPA) and Vendor Risk Management (VRM) Process.
Helping maintain an AFC compliance staff awareness culture by providing appropriate training to staff and arranging training by other regional leads for Sanctions & Embargoes, ABC and AFI. Oversight of local Training and ensure that AFC Training requirements are met in conjunction with the aforementioned leads.
Developing and maintaining the AFC related Internal Control Framework under advice from Regional AFC Risks & Controls to ensure adequate monitoring and control measures are implemented, report on any findings and advise management on remedial actions to take.
Complying with the requirements set by the AFC Global Controls Programme. Develop and carry out adequate controls to ensure that all applicable legal and regulatory AFC requirements are being adhered to in their jurisdiction
AML:
Maintaining especially an adequate Internal Control Framework for Unusual and/or Suspicious Transactions in terms of organization, administration systems and controls to ensure properly and timely detection, investigation and reporting of unusual and/or suspicious transactions or activities to Saudi FIU in compliance with Saudi AML Law.
Implementing adequate monitoring – research /surveillance tools.
Discharging the responsibilities of AFC as set out under global KYC policies for divisions present in the jurisdiction.
Deciding on new or existing clients that are escalated, or decide to escalate further.
Tracking and following-up on the conditions that have been imposed as part of the KYC approval.
Following-up with the Business on status of Regular Reviews and obtain relevant MIS from the Business.
Sanctions:
Monitoring local regulatory sanctions developments and notifying relevant changes and specifications to the Regional Head of Sanctions.
Discharging the responsibilities of the Group Embargo Office locally as set out in the Group Embargo Policy and in the Special Risk Country Policy, in particular, ensuring implementation of applicable sanctions requirements on a country level.
Anti-Fraud:
AFCO locally must assume and promote AFC’s responsibility for anti-fraud in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional AFI teams.
In those locations where the AFCO has dedicated AF&I headcount, local AFI will undertake certain anti-fraud tasks locally in relation to these responsibilities, as appropriate (based on resource level and capability in relation to the issue in question) and as determined by the relevant Regional Head of AF&I. (N/A)
In Saudi Arabia where the AFCO has no dedicated AF&I headcount, the AFCO must refer all fraud matters to the relevant Regional Head of AF&I who will provide support in delivery against these anti-fraud responsibilities remotely from a regional level. (Banking Secrecy applied).
Anti-Bribery & Corruption:
AFCO locally must assume and promote AFC’s responsibility for anti-bribery & corruption in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional ABC teams.
In those locations where the AFCO has dedicated ABC headcount, local ABC will undertake certain anti-bribery and corruption tasks locally in relation to these responsibilities, as appropriate (based on resource level and capability in relation to the issue in question) and as determined by the relevant Regional Head of ABC. (N/A)
In Saudi Arabia where the AFCO has no dedicated ABC headcount, the AFCO must refer all bribery and corruption matters to the relevant Regional Head of ABC who will provide support in delivery against these anti-bribery & corruption responsibilities remotely from a regional level. (Banking Secrecy applied).
Ensuring that AFC Employee Reliability Requirements are met.
Ensuring that local record keeping processes are in alignment with the AFC related legislative, SAMA regulatory and internal requirements.
Providing input for MI reports requested by Global AFC or the AFC reporting function.
Implementing any Governance related controls, processes and procedures as directed by the AFC Governance function.
Ensuring the local implementation of any country, regional or global AFC projects and programs in conjunction with the relevant regional leads.
Your skills and experience:
Between 2 and 3 years work experience preferable within SAMA regulated financial institution.
Fluent in written and spoken English
Experience working as Compliance Officer in a local or international financial institution or within a Regulatory Authority – desirable but not essential
Familiar with Compliance related laws and regulations,
Good personality, comfortable with challenging anyone about any action in an appropriate and balanced manner
Able to handle stressful situations with internal clients and regulators whilst maintaining a professional approach to problem solving
Capable of building up good connections with local legal, regulatory and public authorities
Able to work in a matrix structure
Adopts a hands-on and proactive approach
Able to partner with Compliance peers and other advisory, risk and control functions
Able to partner with senior management, both within the assigned Deutsche Bank country and within the Deutsche Bank Group
Possesses and demonstrates integrity and discretion
How we’ll support you:
Flexible working to assist you balance your personal priorities
Coaching and support from experts in your team
A culture of continuous learning to aid progression
A range of flexible benefits that you can tailor to suit your needs
Training and development to help you excel in your career
About us and our teams:
Deutsche Bank is the leading German bank with strong European roots and a global network. click here to see what we do.
Deutsche Bank & Diversity
We strive for a culture in which we are empowered to excel together every day. This includes acting responsibly, thinking commercially, taking initiative and working collaboratively.
Together we share and celebrate the successes of our people. Together we are Deutsche Bank Group.
We welcome applications from all people and promote a positive, fair and inclusive work environment.