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 Société Générale 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.
The key purposes of the role are:
· 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 Financial Crime Manager of the Global Banking & Advisory (GLBA) and Global Transaction & Payment Services (GTPS) Advisory Team and other members of the team to maintain and further enhance SG London’s financial crime compliance programme for the GLBA & GTPS departments in line with SG Group Instructions relating to financial crime matters and UK legal and regulatory standards;
· To act as one of the principal points of contact for financial crime advisory, relating to the GLBA & GTPS business line, with a focus on the management of Global Banking and GTPS sanctions and embargoes escalations;
· To represent “SG Wholesale Banking UK” at industry forums pertaining to sanctions; and
· Support the Head of FCU London as requested on Sanctions and Embargoes issues.
Summary of responsibilities
To assist the Financial Crime Manager of the GLBA & GTPS Advisory Team or take responsibility for the following:
o To lead on Sanctions and Embargoes advisory queries, providing written advice on complex queries and engaging with the Group Sanctions function when required;
o Identify and propose improvements to current sanctions procedures and controls;
o Provide clear, timely and argued advice on financial crime risk areas to the first line of defence / GLBA & GTPS business units;
o Proactively develop relationships with GLBA & GTPS Compliance Advisors and Heads of Business so that there is a good understanding of the business and the support required from the Financial Crime Unit;
o Advising key business stakeholders on complex financial crime issues;
o Prioritise GLBA work streams, engaging with the business and presenting solutions;
o Ensuring AML, embargoes and sanctions, bribery and corruption, and reputational risk considerations are appropriately considered as part of advising the GLBA & GTPS business units;
o Developing, implementing and managing the anti-money laundering strategy within the UK covering anti-money laundering, terrorist financing, bribery and corruption. To liaise with SG Group Compliance in Paris in respect of that strategy;
o Developing and overseeing relevant training to high risk areas business units in the GLBA and GTPS Teams;
o Providing advice, direction and training to the KYC function;
o Approving high risk accounts referred by the KYC team to the FCU, analysing the completed due diligence and, were appropriate, undertaking additional desktop research, devising conclusions and presenting complex findings to senior management;
o Overseeing and, where appropriate, undertaking, the internal investigation of issues arising and suspicious activity referrals which may have money laundering implications;
o Overseeing the processes associated with financial crime investigations, follow-up of recommendations arising from investigations, and maintaining an up to date log of the status of investigations;
o 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;
o 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;
o 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;
o 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;
o 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; and
o Where required to deputise for the GLBA & GTPS team lead, acting an escalation point for the team.
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.