Regional Head of Sanctions & Embargoes, APAC

The Regional Head of Sanctions & Embargoes (“HoS”) has responsibility for the Asia Pacific region in assisting the Regional Head of Financial Crime Unit (“FCU”) in maintaining the SG Group FCU Policy standards on Sanctions and Embargoes (“S&E”); ensuring SG Group remains regulatory compliant in all FCU S&E related matters.

In particular, the post holder will be one of the subject matter experts within the APAC Regional S&E team, providing S&E expert advice to the business lines and support functions on a day-to-day basis.

The post holder is also expected to help implementing S&E policies and procedures, keep senior management informed of S&E related matters and risks, contribute to the training and awareness program and undertake ad hoc projects to enhance on an ongoing basis the Sanctions Compliance program.

Responsibilities

The Head of Sanctions serves as the primary S&E subject matter expert and is responsible for implementing and overseeing the controls and operations of the Sanctions Compliance program for the Asia Business Unit ("BU"). The Head of Sanctions reports hierarchically to the Regional Head of FCU, APAC and functionally to the Deputy Head of Group Sanctions Compliance (CPLE/FCC/EMB). The Head of Sanctions role includes the following from S&E compliance perspective and by reference to the Asia BU:

Normative Framework

• Ensure implementation of the Group Sanctions Policy and Procedure;
• Draft and distribute other S&E related policies/procedures, where needed;
• Define asset freezing control framework, and notify Group Sanctions Compliance of frozen accounts;
• Provide advice regarding the correct implementation of policies or regulations;
• Supervise the implementation of sanctions compliance framework across the Asia BU and ensure the above missions are achieved at Asia BU / entities level.

Filtering Process

• Have an oversight on the local filtering tool, if applicable;
• Identify the databases/ transactions systems which must be filtered;
• Develop any filtering action plans aimed at enhancing the filtering process, if applicable;

Deal Flow & Advisory

• Monitor S&E related information received from SG entities within the Asia BU and advise on escalated customer files and transactions (including trade finance transactions, syndicated loans, debt issuances etc.) in accordance with the Group Sanctions escalation criteria, and where applicable further escalate such files and transactions to Group Sanctions Compliance;
• Escalate to Group Sanctions Compliance all files that require contact with the French Treasury in France or OFAC in the U.S.;
• Provide technical advice on S&E matters (e.g.  on Dispensations, New Product Committees, filtering), liaise with Group Sanctions Compliance as and when needed.

Alert Management

• Analyze and follow up on the processing of Level 2 Alerts (transactional and referential) that are escalated to Regional Sanctions and Embargoes team, APAC and determine whether these alerts should be escalated to Group Sanctions Compliance in accordance with the Group Sanctions escalation criteria (when these Level 2 Alerts are not directly escalated to Group Sanctions Compliance);

Oversight & Governance

• Coordinate with Asia BU entities through an appropriate governance;  
• Perform follow-up of designated individuals and entities and support to the deployment of S&E requirements;
• Monitor Financial Crime Committees of SG entities for consistency with Group Sanctions Compliance’s guidelines on run-the-bank committees, including ensure proper reporting of Management Information (KRI/KPI) to local management via adequate committees;  
• Contribute and attend to S&E related committees both at Regional and Group levels and represent the APAC Regional S&E team in other governance forums as and when needed;
• Contribute to relevant regulatory reporting made by Group Sanctions Compliance through the consolidation of relevant information escalated by entities;

Risk Assessment

• Lead the Compliance Risk Assessment exercise (“COMPASS”) and contribute to writing and review of the report for the BU;
• Assess Sanctions risk within the BU and escalate areas of risks and mitigated measures;
• Provide advice in view of New Product Committees to conduct sanctions risk assessment;
• Check and challenge actions taken at entity level to manage sanctions risks based on COMPASS;

Training

• Deploy the Group Sanctions Training Plan;
• Deliver targeted S&E Training to SG employees;

Other

• Ensuring an adequate level of resources, both from a qualitative and quantitative standpoint, necessary to the good functioning of the Sanctions Compliance program through completion of the Group S&E capacity planning exercise.