Description of the Business Line or Department
Mission Statement of GBS Compliance:
To enhance and maintain a robust compliance framework, in partnership with all stakeholders, to execute the firm’s strategy in accordance with its risk appetite, regulatory expectations and industry best practices.
In order to achieve its mission statement, GBS Compliance activities are centred around five key objectives, in support of senior management, business lines and resource functions, where the business lines have first level accountability and responsibility, and where GBS Compliance’s responsibility is with respect to compliance, reputational and conduct risk matters. These five key objectives are as follows:
Providing advice and policy development
Facilitating knowledge and awareness
Undertaking monitoring and surveillance activities
Performing risk assessment, review and control activities
Managing the relations with regulators
Summary of the key purposes of the role
The Financial Crime Unit (‘FCU’) is part of the wider Compliance function. It is responsible for providing advice and guidance to business management for the SG investment banking business in London (SG London Branch, SG International Ltd, Lyxor Asset Management UK LLP and Descartes Trading SA – collectively “SG London”) on the financial crime’s risks faced by their business and providing an oversight function on the effectiveness of mitigation controls and processes.
The key purposes of the role is 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;
Summary of responsibilities
Provide clear, timely and argued advice on financial crime risk areas to the first line of defence across SGLB
Approving high risk accounts referred by the KYC team to the Financial Crime Unit (FCU), analysing the completed due diligence and, were appropriate, undertaking additional desktop research, devising conclusions and presenting complex findings to the relevant senior management function;
Ensuring that AML and KYC policies comply with UK requirements within SG London 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 SG London covering anti-money laundering, terrorist financing, bribery and corruption. To liaise with SG Group Compliance in Paris in respect of that strategy;
Providing advice, direction and training to the KYC department;
Overseeing and, where appropriate, undertaking, the internal investigation of issues and suspicious activity referrals which may have money laundering implications;
Overseeing the processes associated with AML investigations, 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;
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;
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 SG London; and
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 Group guidance and advice as required.