Financial Crimes Consultant (EMEA Anti-Bribery and Corruption & Tax evasion)
Wells Fargo & Company (NYSE: WFC) is a leading global financial services company with $2.0 trillion in assets and offices in over 37 countries. Founded in 1852 and headquartered in San Francisco, Wells Fargo provides asset management, capital raising and advisory, financing, foreign exchange, payments, risk management, and trade finance services to support customers who conduct business in the global economy. At Wells Fargo, we want to satisfy our customers' financial needs and help them succeed financially. We also value the viewpoints of our team members and encourage them to be their best. Join our diverse and inclusive team where you will feel valued and inspired to contribute your unique skills and experience. We are looking for talented people who will put our customers at the center of everything we do. Help us build a better Wells Fargo. It all begins with outstanding talent. It all begins with you. Learn more at our International Careers website .
Market Job Description
This role will support the EMEA Anti-Bribery and Corruption Manager to ensure that all day-to-day second line of defence programme controls are performed across both the Anti-Bribery and Corruption Programme ('ABC') and Facilitation of Tax Evasion Programme ('FTE').
FCRM is tasked with the oversight and monitoring of both the ABC and FTE programmes across all legal entities within the EMEA region and across both wholesale and non-wholesale lines of business.
Market Skills and Certifications Responsibilities
- Assists with the monitoring of all aspects of the EMEA risk-based Anti-Bribery and Corruption programme to assure compliance with regional, national, legal and regulatory requirements, with particular focus on the UK Bribery Act (2010) and the Foreign Corrupt Practices Act (1977).
- Assists with the monitoring of all aspects of the EMEA FTE Programme to assure compliance with regional, national, legal and regulatory requirements, with particular focus on the UK Criminal Finance Act 2017.
- Works with all LOB's and legal entities in EMEA to provide subject matter expertise and advice on the current ABC Corporate Policy, Wholesale and Non-Wholesale Policies, EMEA ABC Procedures, EMEA FTE Procedure and specifically focusing on gifts, entertainment, hospitality, sponsorships, donations and third party Intermediary due diligence.
- Prepares ABC and FTE programme related management information for ad hoc requests and on a periodic basis for legal entity, LOB and enterprise reporting deadlines.
- Assists with the monitoring of legal entity service level agreements, KRI's, KPI's and identifies red flags, and trend analysis based on current and historic data for senior management review.
- Assists with drafting of new controls and revising existing controls for IRM within the SHRP tool and performing high-risk control reviews to ensure that controls are operating effectively.
- Ensures that all risk assessment procedures, documentation, templates and resources such as the SharePoint site are refreshed on an annual basis to ensure that the IRA process runs efficiently and to agreed deadlines by First line defence teams.
- Assists with the ABC and FTC Risk Assessment process for EMEA by providing support to all LOB's to ensure they submit their LOB risk assessments on a timely basis and that data and MI is credibly challenged prior to the EMEA IRA submission. Provides credible challenge to LOB and the first line of defence teams that new products, business initiatives, business activities, projects and risk assessments, with moderate to high bribery and corruption risk are identified, assessed and mitigated by the LOB.
- Undertakes reviews of Wells Fargo's high-risk cases and escalations from both an ABC and tax evasion risk assessment perspective and collaborates with LOB owners to ensure this risk is mitigated. Assists with logging, tracking and gathering of high-risk MI cases for all of the ABC and FTC processes.
- Assists with the delivery, publication and communication of new and revised policies, procedures, desk aids, job aids, newsletter updates, SharePoint and Intranet pages and the control framework. In addition, assists with revising both the EMEA ABC and FTE training materials on an annual basis and joining the ABC Manager in providing face to face and/or live training where required.
- Assists with horizon scanning to capture key legal, regulatory or industry developments, lessons learnt and provides newsletters/briefing materials as required by key EMEA stakeholders.
- Assists with gap analyses to ensure new ABC and FTE regulations and legislation are reviewed
- Where required, assist with internal investigations relating to Anti-Bribery and corruption and tax evasion.
- Assists with information gathering and collation of sample data and supporting documentation as requested by Internal Audit, Monitoring and Validation testing teams, WEBCO, ABC-Governance or other group as required.
- Participates in new and existing projects that may be sponsored by EMEA FCRM, ABC-Governance, or other relevant stakeholders that may have rollout deadlines or key milestones that have to be met within region that may affect the EMEA ABC Programme or FTE Programme directly or indirectly.
We Value Diversity
At Wells Fargo, we believe in diversity and inclusion in the workplace; accordingly, we welcome applications for employment from all qualified candidates, regardless of race, color, gender, national or ethnic origin, age, disability, religion, sexual orientation, gender identity or any other status protected by applicable law. We comply with all applicable laws in every jurisdiction in which we operate.