Regional Head of FCC & Bahrain MLRO Regional Head of FCC & Bahrain MLRO …

in Manama, Capital Governorate, Bahrain
Permanent, Full time
Last application, 02 Oct 19
in Manama, Capital Governorate, Bahrain
Permanent, Full time
Last application, 02 Oct 19
Job Purpose:
  • Responsible maintenance and implementation of all aspects of the Group’s Anti-Money Laundering/CTF policies and procedures/Sanctions and Financial Crime Programme in Bahrain.
  • Support Financial Crime Compliance (FCC) Advisory Officer in executing on and facilitating compliance with CBB and applicable financial crime regulations, rules and expectations of regulators
  • Report, escalate and provide assurance to the senior management in Bahrain on financial crime issues requiring attention

Principal Responsibilities, Accountabilities and Deliverables of Role:

  • Support Senior Management and the Board in discharging their FCC responsibilities through review of MLRO related MI and outputs in line with Group policy and standards. Success will be measured by an enhanced MLRO team oversight and ability to proactively engage with other departments/functions to comply with the Bank FCC policy and standards
  • At all times, act with due care, skill and diligence to ensure compliance with the Bank's risk culture, policies and procedures, Code of Conduct and Values. Ensure a climate of openness, transparency and accountability for compliance with external regulations and internal risk policies and procedures, where issues are raised and escalated, as appropriate and required, in a timely manner
  • Ensure that stakeholders and reports are educated on risk and compliance matters and that all employees in reporting line complete mandatory training to schedule
  • Ensure that policies and procedures for your area(s) of responsibility are clearly documented, stored in an accessible manner, and kept up to date
  • Participate in exercises to rehearse the Bank’s response to an emergency situation (i.e. evacuation exercises and Business Continuity tests)
  • Support the Group Financial Crime Officer (GFCO) in implementing and executing the Group’s financial crime compliance policies and procedures on an ongoing basis including to keep abreast of product or market related developments and changes to local regulations and international best practice
  • Providing financial crime compliance advice, guidance and direction to departments in Bahrain 
  • Supporting the GFCO in acting as the Bank’s  contact and reporting officer with the regulatory authorities with respect to financial crime compliance
  • To report to management on financial crime issues requiring attention including internal control and/or system weaknesses, updates to financial crime policies and procedures, and oversight of financial crime for Bahrain
  • Review, advise on, action “unusual/suspicious” transactions and alerts generated from financial crime systems in role of MLRO, and ensure and assure appropriate action including exiting, maintaining or enhanced monitoring of relationships
  • Lead, drive and develop the MLRO team in Bahrain by ensuring they understand and fulfil their job roles and responsibilities, and are appropriately capacitised and skilled. Success is measured by outcomes of their deliverables in their job responsibilities
  • Coordinating the annual review of Bahrain Financial Crime Compliance (“Agreed Upon Procedures”) in conjunction with our external auditors including review of findings arising from the review and ensuring and coordinating corrective action
  • Support, review and action any audit and/or inspection reports or reviews on financial crime compliance including follow up, ensuring and assuring corrective actions taken 
  • Support the testing and implementation of new reports and financial crime related systems for Bahrain, including supporting the GFCO in ownership of systems and procedures governing their use
  • Lead and drive implementation of FCEP policies and standards particularly to transaction monitoring, transaction screening, suspicious activity reporting, CDD and C-RAM. Working together with the Group to successfully implement the FCEP programme according to timelines and on a risk based approach
  • Provide MLRO support for the KPIs as part of implementation of the Board approved Risk Appetite
  • Developing and Implementing FATCA ongoing compliance programme
  • Providing advisory support to the compliance and business on FATCA
  • Complying and distributing FATCA MI to appropriate risk committees
  • Analysing legal entity structures, preparing withholding certificates and registering FFIs if required
  • Conducting gap analyses to identify systems and processes that must be updated and ensuring necessary policies and procedures are updated periodically
  • Developing implementation plans for the changes required for FATCA compliance
  • Ensure that proper FATCA due diligence is performed on account holders and remediate non-compliant accounts
  • Conducting necessary/periodic training
  • Produce periodic reports internally to Lead FFI RO
  • Produce Periodic reports externally to the IRS/and or local authorities
  • Working with Internal Audit in resolving all findings with regards to FATCA ensure that all FATCA issues are addressed.


  • Provide timely, practical, value added Financial Crime advisory to business and functional Units
  • Support the Bank in development and implementation of the Financial Crime framework, policies and procedures, in partnership with the Group document owners
  • Demonstrate proactive identification and management of key regulatory risks and issues in areas under responsibility
  • Self-identification of compliance related audit issues in areas under responsibility
  • Acceptable rating for audits on Financial Crime or Financial Crime related issues
  • Closure of outstanding audit issues within stipulated time period or as agreed with Internal Audit.

Job Requirements:


At least eight years compliance or financial crime experience with deep working knowledge of financial crime issues and operations

Personal Attributes

Pragmatic, attention to detail