'As AML Compliance Officer of SG Amsterdam Branch you will be mainly responsible for:
- In close cooperation with the Head of Compliance, conducting the annual Compliance Risk Assessment for the activities present in the branch in order to analyze the entity’s specific exposure to risks of money laundering, sanctions and terrorist financing and detect possible gaps in the existing Compliance framework; as well as setting up the resulting action plans;
- Actively and independently contributing to Business decisions by providing on-the-ground support and guidance on the practical application of the relevant AML/CTF laws and regulations; this includes constantly challenging the Business to demonstrate compliance with the required standards;
- Drafting Compliance opinion with regards to on-boarding and/or review of customers / counterparties; where required, liaising with the business lines, KYC teams and central Financial Crime Unit (FCU) department;
- Formulating Compliance opinion on the aspects of (Financial Crime) Compliance risks as well as potential reputational risk presented by new products and/or services; or by specific transactions/situations upon request of the business;
- Independently overseeing and challenging the effective management of Financial Crime Compliance-related risks and controls within agreed risk appetite; that means proactively identifying potential or actual Compliance risks, ensuring timely escalation to the Head of Compliance and proposing remediation actions to address root causes and making sure the risks identified are back within the bank’s risk appetite;
- Supporting the Head of Compliance in maintaining the oversight over the offshored Compliance and KYC activities, including but not limited to the continuous provision of guidance and training to the operational teams involved in offshored services;
- Drafting and/or updating local compliance policies and procedures in line with the Group's instructions and/or local regulatory laws and regulations;
- In close cooperation with the local legal department, contributing to the maintanance of the local Legal Watch by closely following-up on any new legal/regulatory developments impacting the branch, advising local stakeholders of any new regulations impacting their businesses and/or providing impact assessment analysis for any Compliance-related topics (where required);
- Supervising and mentoring a junior team member (VIE) with regards to the allocated tasks, including but not limited to performing Compliance investigation on escalated unusual transactions/Transaction Monitoring alerts and providing Compliance opinion on new client on-boarding / client reviews;
- Declaring unusual transactions to FIU Nederland, making sure they are well substantiated, reported in a timely manner and easily retrievable upon the regulator's request;
- Drafting regulatory reports and discussing the outcome with the Head of Compliance;
- Providing ad-hoc and/or regular training to Business / Business Support functions;
- Acting as a Subject Matter Expert (SME) in the allocated topics and ensuring effective knowledge sharing in these areas between team members;
- Actively contributing to and participating in various enterprise-wide as well as local projects with a view to assessing their impact and making recommendations from a financial crime compliance perspective;
- Deputizing for the Head of Compliance (as required) at senior stakeholder forums.
As Deputy CABCO (Client Anti-Corruption Officer) of the Branch you will be responsible for:
- Validating KYC deal flow files (onboarding, reviews, and one-off) with ABC flag; where required, escalating files towards Group Compliance or to CABCO BU/SU;
- Advising the BUs on the relevant ABC policies and procedures as well as providing training (where required);
- Participating in various Group and local ABC committees, if and where required;
'As Internal Data Protection Correspondent (DPC) of the Branch (as per SG Code, Book B, Title VI Compliance Principles) you will be responsible for:
GDPR Advisory: in close cooperation with the external DPO and Group DPO, provide BU/SU advisory on various data protection-related topics, with a specific view on the Dutch gold-plating of GDPR and guidelines issued by the local DPA.
Risk Assessment: performing an annual Compliance risk assessment of the local GDPR framework and setting up resulting action plans;
Register (Data Protection Register): Measuring presence and effectiveness of controls to be executed by LOD1: making sure that the register is properly maintained, complete, accurate and reliable.
Private Impact Assessment (PIA): Measuring presence and effectiveness of controls to be implemented by LOD1 on PIA and providing DPC opinion.
Exercise of Rights: Checking that the process exists and GDPR requests are properly recorded and dealt with by LOD1.
-Maintaining breach record and handover to the DPA (if required) and informing the DPO (if and where required);
- Applying the breach assessment methodology (written by DPO Office), by fulfilling for each reported breach the DPO Office questionnaire;
- Checking measures presence and effectiveness;
- Sending a Quarterly Data Breach report to the Group DPO Office.
Internal and external contracts: Seeking information by LOD1 of difficulties of implementation.
Training: Gathering information at LOD1 on staff trained and materials.
Regulatory and market watch: Seeking information to external DPO or to DPO Office of market watch impacts.
Contact with local DPA:
- Seeking information from LOD1 or DPO of any DPA demand.
- Informing DPO Office in case of DPA demand.
Group-wide GDPR projects:
- In close cooperating with the Group/EMEA DPO and an external DPO for the branch, actively participating and contributing to various Group-wide projects and initiatives aimed at strenghtening the local GDRP framework and/or where these initiatives present a GDPR angle.