Description of the Business Line or Department
The Compliance Service Unit (CPLE) is responsible for the definition and consistency of the compliance risk prevention and control system, and for coordinating the framework aimed at preventing, identifying, assessing and controlling reputational risk.
In conjunction with the Business Units and other Service Units (BU/SUs), CPLE performs the following tasks with respect to compliance risk:
- Defining and implementing the overall normative framework of the Compliance service and monitors its implementation;
- Defining procedures and implementing a framework to ensure compliance with respect to compliance risks;
- Awareness-raising among Group employees regarding compliance risk and the strengthening of the compliance culture within the Group;
- Mapping and analysing Group compliance risk and general vigilance regarding issues likely to harm the Group's reputation or that of one of its activities;
- Performing the second-level control and supervision of the framework, including independently assessing compliance risk management within the entities/activities with a major impact on the Group's risk profile, and individually with respect to regulated employees, in compliance with the applicable regulations;
- Monitoring relations with supervisory and regulatory authorities, and representing the Societe Generale Group to these authorities, not including supervisory and regulatory authorities where the Legal function (SEGL/JUR) organises and coordinates the monitoring of these relations, in particular the Autorite de Controle Prudentiel et de Resolution (ACPR) and the European Central bank (ECB);
- Consolidating and monitoring significant compliance events in the entities
Summary of the key purposes of the role
The Financial Crime Unit (“FCU”) provides business management within SG London Branch (“SGLB”), SG International Ltd (“SGIL”) and Lyxor Asset Management UK LLP (“Lyxor UK”) (collectively these legal entities will be referred to as “SG Wholesale Banking UK”) with technical advice on the management of the firms’ money laundering/terrorist financing, bribery and corruption (“ABC”); embargoes and sanctions (“E&S”); and Tax Evasion and Facilitation Offence (“TEFO”) risk. In addition, the Unit undertakes an oversight role to assist management in the assessment of the effectiveness of the policies, procedures and controls designed to mitigate these risks. Key purpose of the role:
The key purposes of the role:
- To assist with the implementation and management of the anti-financial crime strategy within the UK covering anti-money laundering, terrorist financing, bribery and corruption and economic sanctions;
- To work with the Head of the Financial Crime Unit and other members of the team to maintain and further enhance SG London’s financial crime compliance programme in line with SG Group Instructions relating to financial crime matters and UK legal and regulatory standards;
Summary of responsibilities
To assist the Head of the Financial Crime Unit or take responsibility for the following:
- Ensuring that AML policies comply with UK requirements within SGCIB UK and liaising with SGUK AML functions to ensure consistency. In addition, to liaise with the SG Group Compliance function in Paris in respect of these policies;
- Developing, implementing and managing the anti-money laundering strategy within the UK covering anti-money laundering and terrorist financing. To liaise with SG Group Compliance in Paris in respect of that strategy;
- Advising local and Group management on complex anti-money laundering issues;
- Developing and maintaining appropriate controls for the Monitoring function;
- Overseeing and, where appropriate, undertaking, the internal investigation of issues arising and suspicious activity referrals which may have money laundering implications.
- Overseeing the processes associated with AML investigations, including the investigations action plan, follow-up of recommendations arising from investigations, and maintaining an up to date log of the status of investigations
- Submitting reports to NCA and FCA, as required, and management of the follow-up process, to ensure that the responses from such external agencies is appropriately applied, maintaining all associated records in accordance with legal and regulatory requirements
- Developing, implementing and overseeing review programmes, including the monitoring and surveillance of AML within SGCIB UK, ensuring timely identification of risks and the development of cost- effective and efficient counter-measures
- Ensuring AML, embargoes and sanctions, and bribery and corruption considerations are appropriately considered as part of the new Product Committee process, and influencing the approval or otherwise of new products from an AML perspective;
- Implementing and maintaining appropriate management information for AML; including the completion of an annual report to senior management on the operation and effectiveness of the SGCIB UK’s AML systems and controls;
- Advising management on the planning, review and design of sanction/embargoes controls;
- Developing and overseeing relevant training.
- Maintaining a detailed working knowledge of the FCA rules and regulations, and UK AML, ABC and embargo and sanctions related legislation, and a broad awareness of AMF, ACPR and other regulatory and exchange rules and regulations as required
- Contributing to the development of the annual department strategy and Compliance Plan
- Uphold the 11 FCA Principles for Business and the 7 Statements of Principle for Senior Managers in order to promote a culture of compliance and treating customers fairly within SGCIB UK
- Actively promote the business principles both within, and externally to, the Compliance Department
- Attendance at forums of, and participation in, initiatives driven forward by, trade associations and other industry bodies, ensuring that SG's views on regulatory developments which could impact on its business in the UK are provided as part of any consultation initiatives and that relevant benchmarking is undertaken and played back within Société Générale as appropriate.
- Management of the proactive participation in the maintenance of the risk cartography, ensuring that the inherent regulatory risks posed by business activity are determined, the mitigating factors assessed to determine the residual risk and the actions required to further mitigate, or reduce, the regulatory risk
Level of Autonomy and Authority
Role involves acting with initiative and autonomy, where appropriate, ensuring proactive upward reporting of relevant issues, as well as seeking guidance and advice as required.