Responsibilities
Level of Autonomy and Authority
- The Director of 2nd Level Control will have to manage autonomously the responsibilities set out in this job description. The Director shall not make decisions which would have an impact on the delivery of the mission without referring to the Regional Head of the 2nd Level Control and the Regional Head of APAC Compliance and getting their approvals. The Director shall escalate any high risk/issue or work resistance in the execution of the review without delay to the Regional Head of the 2nd Level Control. This role reports to the Regional Head of CPLE/CTL of APAC.
Summary of the key purposes of the role
- Definition of an annual risk-based Compliance control plan for APAC
- Supervise and deliver Compliance reviews as required by the annual control plan
- Ensure Compliance risks are identified and managed in a timely manner
- Ensure timely tracking, resolution and closure validation of CTL recommendations
- Governance and reporting management.
Summary of responsibilities
Definition of an annual risk-based Compliance control plan for APAC
- Adopt a strong risk-based approach.
- Analyze the results of the risk assessment campaign, key incidents, external enforcements, results of previous reviews, regulatory agenda and detect weak areas or process at risk. Narrow down the selection of priorities with the contribution of key compliance and business stakeholders across the region.
- Ensure alignment with Group’s instruction on the construction of annual control plan for APAC.
- Collaborate with other regions on planning and priorities alignment for similar risks and/or activities when relevant.
- Consult all key stakeholders including local Compliance officers of each legal entities covered, Business and Support functions in the region and LOD3.
Supervise and/or deliver Compliance reviews as required by the annual control plan
- Manage end to end thematic/cyclical/desk review activities by:
o Performing and supervising review activities, including scoping, testing, issue clearance, reporting.
o Ensuring appropriate scoping of review activities to detect non-compliance and control deficiencies.
o Delivering work on schedule and in accordance with CTL standards and methodology.
o Escalating any risk/issue to the Regional Head of CTL on a timely basis, including where there is a risk of delayed implementation or work resistance from the relevant stakeholders.
o Reviewing draft reports to, and obtaining clearance from, the Regional Head of CTL prior to issuance and communication to the relevant business and Compliance stakeholders.
o Managing distribution of the review report to the relevant stakeholders and the recording of the issues/actions/recommendations in the database.
- Provide periodic updates of the review status in weekly team meetings and update the team’s activity report on a monthly basis. Comment on key risks/issues identified and highlight any potential slippage, and/or provide justification for slippage, if the anticipated delivery schedule is not going to be met.
- Ensure timely tracking of CTL issues/action plans/recommendations and provide updated status in the recording database on a regular basis and escalate before overdue.
- Maintain adequate and accurate working papers to evidence the review execution and support issues/actions/recommendations.
Governance and reporting management
- Contribute to SG Internal control committees (Global or regional) to debrief key issues identified from APAC CTL reviews.
- Manage regular reporting process to communicate results of CTL reviews to local Compliance officers of each APAC legal entities covered and Global CPLE/CTL teams.
- Contribute to the oversight of compliance by attending regular meetings with experts at Regional, Wholesale and Global level.
- Attend regular meetings related to internal control framework to stay on top of the Bank’s evolution in permanent control system.
- Contribute to Global change management projects/ initiatives (new tools, methodology, offshoring, data analytics) and its implementation in the region.
- Forster continuous improvement and simplification of regional CTL tasks, templates and processes.
- Respond to requests from LOD3 and regulatory bodies.
Teamwork
- Collaborate and work with all staff involved in the execution of the reviews, providing support throughout the review life cycle (including the validation of the scoping document, the testing results, the validation/clearance of issues/actions/recommendations, and the issuance of the report).
- Support and share expertise on compliance and/or business specific knowledge/matters.
- Contribute to heighten awareness of major regulatory developments and its impact to the bank’s activities from a risk management perspective.
- Develop and maintain effective partnership and working relationships with relevant stakeholders at all levels of organisation based on an understanding of their concerns, needs and motivations.
Engagement with business line and Compliance stakeholders
- Provide regular updates to key businesses and Compliance stakeholders on the progress of the review and the risks/issues identified during the review period (including proactively participating in business meetings and/or risk committees, if required).
- Maintain updated knowledge of the business line organisation as well as its strategic developments and key projects.
Other responsibilities
- Maintain a detailed and updated working knowledge of the SFC, HKMA, MAS rules and regulations.
- Develop and maintain own training plan to stay abreast of new regulatory requirements and Internal Controls/Policies.
Other responsibilities apply to the role:
- Comply with all Risk and regulatory obligations where relevant
- Responsibility for ensuring that you are fully aware of and adhere to internal Policies that relate to you, your business or other businesses for which you have any level of responsibility.
- Responsibility for reading, understanding and complying with the Company's Conduct and Standards and corresponding regulations. You will be notified of changes to policies in a timely manner through announcements and/or intranet updates.
Profile required
- Minimum of 15 years of relevant work experience in the financial services industry, internal audit/control testing, compliance background
- Experience in execution of projects/reviews with minimum supervision
- Broad business experience and a proven ability to influence
- Demonstrated ability in strong communication, organisational, analytical and people skills
- Proven track record in delivering results, self-starter and ability to manage complex projects a must
- Experience in analysing large datasets, draw valid inferences and present them clearly to key stakeholders
- Have ability to work effectively with both local, regional and global stakeholders
- University Graduate in Law, Bank & Finance or Economics
- Professional diploma or qualifications in Compliance (e.g., ACAMS, AAMLP) and/or Audit (e.g., CPA) preferred
- Fluent English: strong verbal and written communication skills, ability to articulate concisely technical matters
Financial Conduct Authority & Prudential Regulation Authority Conduct Rules
Individual Conduct Rules - All staff covered by Code of Conduct rules are reminded of their obligation to adhere fully to these codes of conduct and failure will be considered as an act of gross misconduct
- RULE 1: You must act with integrity
- RULE 2: You must act with due skill, care and diligence
- RULE 3: You must be open and cooperative with the FCA, the PRA and other regulators
- RULE 4: You must pay due regard to the interests of customers and treat them fairly
- RULE 5: You must observe proper standards of market conduct
Behavioral Skills
- Innovation - Technology: I take new technologies into account in my activities
- Team Spirit - Open mindset/Respect: I listen and share my views and my expertise in an open mode
- Responsibility - Empowerment and Accountability: I give my team the autonomy to make decisions at the appropriate level
- Commitment - Exemplarity: I embody the Group’s values
- Client - Client focus: I put long-term relationship with our clients/internal partners at the center of our actions, whatever my position
- Team Spirit - Synergies: I make developing synergies a priority
HKMA Enhanced Competency Framework (ECF) certification is preferred
Business insight
Company Description
Societe Generale is one of the leading European financial services groups. Based on a diversified and integrated banking model, the Group combines financial strength and proven expertise in innovation with a strategy of sustainable growth. Committed to the positive transformations of the world’s societies and economies, Societe Generale seeks to build together with its clients, a better and sustainable future through responsible and innovative financial solutions. Active in the real economy for over 150 years, with a solid position in Europe and connected to the rest of the world, Societe Generale has over 117,000 employees and supports 25 million individual clients, businesses and institutional investors worldwide (figures as of August 2023). We have a presence in 11 locations across Asia Pacific. With our regional headquarters in Hong Kong – a core hub of the worldwide Societe Generale Group – we employ around 2,300 employees in the region. In addition, Societe Generale's Global Solution Centre (SGGSC) in Bangalore and Chennai supports the Group in Asia Pacific and globally with customised business solutions.
Department Description
CPLE/CTL’s mandate is to oper-ate, within the 3 Lines of Defence model, a 2nd Level Controls and Testing framework, from both a regulatory and financial crime perspective, based around a robust compliance risk assessment, which drives the prioritization of the control plan.
The objective of 2nd Level Controls and Testing is to assess and test independently the adequacy of the 1st and 2nd Lines of defence (LOD1 & LOD2) compliance framework that Business Units (BU) and Support Units (SU) have put in place to mitigate the risks of non-compliance that SG Group is exposed to across its business activities and operations regionally.
The CTL team is positioned as a second line of defence in the bank’s internal control framework and has a specific mandate within Compliance, with the objective to measure, test, detect and report the risk of non-compliance. The responsibilities of the Asia regional team include:
- Collect and analyse compliance risk indicators;
- Build a risk based yearly Control plan for APAC;
- Coordinate the annual Compliance Risk Assessment with Regional and Country Advisory Compliance for Asia;
- Execute Compliance reviews covering wholesale bank activities within Asia;
- Ability to understand local regulatory requirements within Asia
- Monitor the control assessment of the Permanent Supervision in Asia; and
- Deliver recommendations and action plan to enhance the global control framework.
We are an equal opportunities employer and we are proud to make diversity a strength for our company. Societe Generale is committed to recognizing and promoting all talents, regardless of their beliefs, age, disability, parental status, ethnic origin, nationality, gender identity, sexual orientation, membership of a political, religious, trade union or minority organisation, or any other characteristic that could be subject to discrimination.