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”), and SG International Ltd (“SGIL”) (collectively these legal entities will be referred to as “SG London”) 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:
- To act as the embargoes and sanctions (“E&S”) subject matter expert for SG London) reporting directly to the Head of the Financial Crime Unit (“FCU”).
- To have responsibility for the oversight of the E&S control framework for SG London. To monitor the effectiveness of SG London’s Sanctions Compliance Program, and ensure that sanctions related policies, procedures, systems and controls are being complied with, are working effectively and are properly embedded within SG London.
- To represent the FCU at the regular E&S Governance meetings for both SGLB and SGIL, and to present on key E&S matters requiring the attention of the E&S Committees. The respective MLROs for SGLB and SGIL may also attend these meetings.
- To take efforts to continue to ensure that the impact of, and obligations under, UK sanctions legislation are understood within the SG Group and, in particular, within CPLE/FCC.
- To act as the main contact point for all sanctions related matters with Head Office, regulators and government agencies.
Summary of responsibilities
- Maintaining SG London E&S related policies, procedures and guidance notes such that they are in compliance with UK legislation and Head Office Instructions;
- Assessing and managing situations where SG London is unable to apply SG Group policy and controls and needs dispensation from Group requirements;
- Act as the E&S subject matter expert and primary point of contact for SG London. Provide support, advice and guidance on E&S matters as required e.g., material risk and complex E&S issues;
- To represent the FCU at the regular E&S Governance meetings for both SGLB and SGIL, and to present on key E&S matters requiring the attention of the E&S Committees. This to include the collection and presentation of appropriate Key Risk Indicators and other relevant management information;
- Receiving, investigating and reporting E&S related issues escalated by management or staff. Where required this will include reporting to relevant competent authorities and internal incident reporting e.g., OFSI asset freeze, OFSI sanctions breach, OFSI licence application;
- Act as an escalation point for new and existing client due diligence files where material risk and complex E&S issues are identified;
- Escalating to management and Head Office any identified potential weaknesses in the sanctions systems and controls within SG London;
- To assess the E&S risks faced by SGLB and SGIL through both formal and informal risk assessment methodologies;
- Assessing the impact on SG London of forthcoming changes in sanctions regulations;
- Developing and strengthening relationships with the business heads, regional sanctions teams, business units and service units to promote best practice and ensure a good understanding of economic sanctions requirements;
- Identifying sanctions related training needs, developing appropriate tools, drafting training decks and delivering face-to-face training;
- Maintaining oversight arrangements to monitor that business continues to be conducted in compliance with all relevant sanctions obligations. Such arrangements to include effective oversight arrangements for those aspects of the control framework (e.g. static data and transactional screening) which have been ‘off-shored’ by SG London;
- For activity that SG London has ‘off-shored’, prepare and maintain service level agreements and undertake any required risk assessment reviews of this activity.
- Taking responsibility for all Head Office imposed projects and processes which impact on SG London sanctions compliance;
- Draft and execute controls to ensure that sanctions policies and processes are being adhered to;
- Support the MLROs with preparation for internal audit or compliance assurance reviews;
- Review sanctions clauses alongside the legal department, to ensure SG London is sufficiently protected;
- Undertaking capacity planning to ensure SG London has sufficient sanctions resource;
- Liaise with external counsel and other sanctions-related vendors, as required;
- Represent SG London at relevant E&S industry bodies/forums;
- Perform all duties in accordance with the principles outlined in the SG London Code of Conduct, as well as the policies and procedures relevant to your responsibilities, to ensure that you adhere to a culture that treats clients fairly and focuses on the long-term sustainability of client relationships.