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Description of the Business Line or Department
Mission Statement of GBS Compliance:
To enhance and maintain a robust compliance framework, in partnership with all stakeholders, to execute the firm's strategy in accordance with its risk appetite, regulatory expectations and industry best practices.
In order to achieve its mission statement, GBS Compliance activities are centred around five key objectives, in support of senior management, business lines and resource functions, where the business lines have first level accountability and responsibility, and where GBS Compliance's responsibility is with respect to compliance, reputational and conduct risk matters. These five key objectives are as follows:
Providing advice and policy developmentFacilitating knowledge and awarenessUndertaking monitoring and surveillance activitiesPerforming risk assessment, review and control activitiesManaging the relations with regulators
Summary of the key purposes of the role
The Financial Crime Unit (‘FCU') is part of the wider Compliance function. It is responsible for providing advice and guidance to business management for the SG investment banking business in London (SG London Branch, SG International Ltd, Lyxor Asset Management UK LLP and Descartes Trading SA – collectively “SG London”) on the financial crimes risks faced by their business and providing an oversight function on the effectiveness of mitigation controls and processes.
The key purposes of the role is:
To assist with the implementation and management of the anti-financial crime strategy within the UK covering anti-money laundering, terrorist financing, bribery and corruption and economic sanctions; To work with the GLFI Team Lead and other members of the team to maintain and further enhance SG London's financial crime compliance programme for the Global Finance department in line with SG Group Instructions relating to financial crime matters and UK legal and regulatory standards; and
To act as one of the principal points of contact for financial crime matters relating to the GLFI business line, with a particular focus on the management of Global Finance sanctions escalations
Summary of responsibilities
To assist the Global Finance Tram Lead or take responsibility for the following:
Provide clear, timely and argued advice on financial crime risk areas to the first line of defence / Global Finance business units; Proactively develop relationships with Global Finance Compliance Advisors and Heads of Business so that there is a good understanding of the business and the support required from the Financial Crime Unit; Advising key business stakeholders on complex anti-money laundering issues;
To lead on sanctions advisory queries, providing written advice on complex queries and engaging with the Group Sanctions function when required;
Identify and propose improvements to current Financial Crime procedures and controls;
Prioritise Global Finance work streams, engaging with the business and presenting solutions; Ensuring AML, embargoes and sanctions, and bribery and corruption considerations are appropriately considered as part of advising the Global Finance business units;
Ensuring that AML and KYC policies comply with UK requirements within SGCIB UK and liaising with SGUK AML functions to ensure consistency. In addition, to liaise with the SG Group Compliance function in Paris in respect of these policies;
Developing, implementing and managing the anti-money laundering strategy within the UK covering anti-money laundering, terrorist financing, bribery and corruption. To liaise with SG Group Compliance in Paris in respect of that strategy; Developing and overseeing relevant training to high risk areas business units in the Global Finance team;
Providing advice, direction and training to the KYC function; Approving high risk accounts referred by the KYC team to the FCU, analysing the completed due diligence and, were appropriate, undertaking additional desktop research, devising conclusions and presenting complex findings to senior management;
Overseeing and, where appropriate, undertaking, the internal investigation of issues arising and suspicious activity referrals which may have money laundering implications; Overseeing the processes associated with AML investigations, follow-up of recommendations arising from investigations, and maintaining an up to date log of the status of investigations; Submitting reports to NCA and FCA, as required, and management of the follow-up process, to ensure that the responses from such external agencies is appropriately applied, maintaining all associated records in accordance with legal and regulatory requirements;Implementing and maintaining appropriate management information for AML; including the completion of an annual report to senior management on the operation and effectiveness of the SGCIB UK's AML systems and controls;
Maintaining a detailed working knowledge of the FCA rules and regulations, and UK AML, ABC and embargo and sanctions related legislation, and a broad awareness of AMF, ACPR and other regulatory and exchange rules and regulations as required;
Uphold the 11 FCA Principles for Business and the 7 Statements of Principle for Senior Managers in order to promote a culture of compliance and treating customers fairly within SGCIB UK;
Attendance at forums of, and participation in, initiatives driven forward by, trade associations and other industry bodies, ensuring that SG's views on regulatory developments which could impact on its business in the UK are provided as part of any consultation initiatives and that relevant benchmarking is undertaken and played back within Société Générale as appropriate;
Management of the proactive participation in the maintenance of the risk cartography, ensuring that the inherent regulatory risks posed by business activity are determined, the mitigating factors assessed to determine the residual risk and the actions required to further mitigate, or reduce, the regulatory risk
Level of Autonomy and Authority
Role involves acting with initiative and autonomy, where appropriate, ensuring proactive upward reporting of relevant issues, as well as seeking Group guidance and advice as required.
Flexibility - Adaptability
Ability to make decisions
Ability to Work Under Pressure Analytical Skills
Leadership Qualities Teamwork In-depth working knowledge of FCA and other regulatory rules In-depth working knowledge of financial crime related legislation Knowledge of EU directives relating to financial services, as well as broad knowledge of AMF and ACPR rules