• Negotiable
  • Singapore
  • Permanent, Full time
  • Standard Chartered Bank Singapore
  • 25 Apr 18

Director, FCC, Tax Evasion Risk Framework

  • Location: Singapore
  • Salary: Negotiable
  • Job Type: Full time

This role is to support the implementation of the Tax Evasion Risk Framework across the Bank (predominantly focusing on Commercial Bank and Corporate Institutional Bank segments). Travel is required and this may be up to 30%.

Risk management, governance & infrastructure

- Ensure that the Group's risk management framework is adequate to identify, assess and manage the risks of laundering the proceeds of tax evasion
- Equip relevant FCC areas with tax knowledge and awareness required to perform their roles in managing AML risks
- Support the enhancement of existing AML on-boarding controls for tax evasion risk (e.g. oneCDD, tax questionnaires)
- Provide tax expertise in relation to cases and investigations involving clients' tax evasion risks
- Help develop and deliver a scalable and effective communication and training program directed at key functions, businesses (e.g. FCC, Compliance , RMs, Product Teams) and senior management stakeholders
- Support the raising of awareness of tax evasion risks across the organization
- Support the design of surveillance processes so that systems and people are better equipped to identify the laundering of tax evasion
- Work with Group Conduct on instituting tax evasion conduct-related controls in relevant business processes as well as in the bank's Supervisory Framework

Strategic/Event driven

- Assist in developing a proactive framework to respond to any money laundering risks that may arise or be identified through the occurrence of tax amnesties and other events (e.g. Panama Papers) to facilitate efficient management of these to the extent these impact SCB
- Provide subject matter expertise on tax to support relevant teams in undertaking strategic reviews of high-risk businesses, products and geographies to scan for current and emerging risks
- Help maintaining productive relationships with law enforcement bodies and regulators and actively participate in industry forums whilst setting and communicating advocacy approach across the bank
- Assist in the automation of processes to support the identification and management of the risks of laundering the proceeds of tax evasion (e.g. tax typologies, red flags)

Corporate Criminal Offence (CCO) programme

Support the implementation of the UK CCO programme throughout SCB including:
o Enhancement of the Tax Evasion Risk Assessment
o Supporting the design and implementation of proportionate risk-based prevention procedures including internal and external reporting mechanisms
o Communication and training of relevant stakeholders (first and second line of RMF)
o Continue to monitor and enhance controls over time, in line with CCO regime (including benchmarking with peers)


* Help to establish and maintain effective processes (including training, advice and support) to ensure that policies, procedures and standards addressing the risks of laundering the proceeds of tax evasion/fraud are effectively implemented and adhered to across all client businesses
People and Talent
* Lead through example and contribute in building the appropriate culture and values.

Key Stakeholders

* Group Tax
* Client Tax Information Compliance (CTIC)
* Compliance
* All key FCC functions
* Businesses including Senior Management
* Risk
* Internal Audit
* Key regulators of the Group (including tax authorities and law enforcement bodies)

Risk Management

* Ensure effective management of the risks of laundering the proceeds of tax fraud/evasion and UK CCO matters, and in collaboration with Group Tax and CTIC (as well as other relevant Functions), effectively manage such issues that have a significant impact on the Bank.
* Collaborate with the other relevant stakeholders (e.g. Group Tax, FCC, CTIC) to anticipate horizon risks that may have a significant impact on the Bank and develop effective strategies to mitigate such horizon risks including global standards for conduct of business.
* In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure senior management in the Bank and relevant regulators are informed and that actions are taken quickly to remediate and/or activities are ceased. Ensure proactive and timely identification, assessment, advice and dissemination of evolving regulatory changes/practices and associated risks, and proactive engagement in regulatory reform. Assist and work closely with relevant teams in relation to investigations concerning the laundering the proceeds of tax fraud/evasion in client businesses.
* Provide reports to relevant Group and Business risk and control committees and management group on key tax evasion/fraud risks and issues.

* Within the Group's overall Risk Management Framework, help to establish and maintain appropriate risk based compliance frameworks for identifying, assessing, managing, monitoring, mitigating and reporting the risks of laundering the proceeds of tax fraud/evasion

Regulatory & Business conduct

* Display exemplary conduct and live by the Group's Values and Code of Conduct.
* Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct, across Standard Chartered Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.
* Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.

Qualifications & Experience

* A corporate tax expert with 10+ years' experience in financial services (Emerging Markets, Africa and China experience preferred)
* An expert understanding of tax issues impacting banking products and structures
* Solid tax risk management background and experience in instituting controls in global banking businesses
* A strong Compliance mindset and ability to influence senior stakeholders
* Solid stakeholder management skills, able to distil complex tax matters succinctly and communicate effectively to non-tax senior stakeholders
* Strong core values and ethics
* A self-starter and outcomes-driven individual that can work with minimal supervision
* Legal and/or accounting qualifications required. Advanced degree in Tax preferred (e.g. Master of Tax)

Singapore Singapore Singapore SG