AML Junior Analyst, BMO Asia

BMO

This role is an entry level (no experience needed) into the quickly expanding Anti-Money Laundering (AML) field and an entry to foreign banks. The salary range is 4000 rmb/month to a maximum of 5000 rmb/month. Non-negotiable requirements are Chinese citizenship (for visa purposes) and advanced English proficiency.


Job Title: AML Junior Analyst
Immediate Manager: Senior AML Business Manager
Next Level Manager:  Head of Enterprise Business Control, Asia
Banking Group / Department:  Enterprise Business Control
Location: BMO Asia (multiple)

MANDATE:
The AML Jr Analyst/Analyst/Sr. Analyst/Specialist is accountable for a variety of tasks related to AML risk-control with a particular focus on completing Know Your Client (KYC) risk due diligence and Enhanced Due Diligence (EDD) risk monitoring (including transactional reviews). This role will maintain an understanding of AML policies, procedures and systems. This role will require the incumbent to understand, in some depth, the various Capital Markets lines of business, products, and customers’ business to determine the likelihood that the use of BMO services is for money-laundering or terrorist financing purposes.

KYC Risk Due Diligence
The incumbent will risk score each client, complete the required documentation and collect EDD/CDD documentation for the files/customers that meet high risk criteria.  The incumbent will also be involved in regular communication with various lines of businesses for documentation, clarifications, and on project work. They will gather information from this and various other sources and will develop an AML file that is complete, well organized and forms the basis for the enhanced due diligence. The incumbent is accountable to ensure all tracking is completed and documented to audit control levels.  As part of the KYC role and separately, the incumbent will need to adjudicate “hits” (to adverse media, sanctions, official lists, crimes, etc.) with adequate analysis recorded in the file.

EDD Risk Due Diligence and Transaction Monitoring
The incumbent is accountable to mitigate and manage risk exposure pertaining to AML/ATF by completing standardized assessments of information and activities associated with accounts that have been identified as high risk.  They will collect and analyze data to assist in determining the extent and materiality of the risk this account and the broader customer relationship presents and will develop recommendations for actions to maintain the account relationship within the defined tolerance level or, if this is not possible, will recommend closure/demarket.   This role will risk score each client, and gather and validate all EDD/CDD documentation for each required account.  The incumbent will maintain account files in a manner that will ensure compliance with the AML/TF customer due diligence operating directive and AML procedures.  The incumbent will provide advice and guidance to the lines of business regarding processes related to high risk accounts to support their efforts to effectively manage risk.

Business Control Support

  • The incumbent will lead, assist and/or support the Department with the following accountabilities where assigned:
  • assist with the design and implementation of solutions to new AML/ATF or other regulatory or policy requirements,
  • assist in projects related to AML/ATF or other business control changes,
  • assist in creating and maintaining AML/ATF or other related procedures,
  • assist with the creation and delivery of training programs,
  • assist with tracking and resolution of AML/ATF or other issues,
  • assist with reviews of new products and initiatives for AML and other assigned regulatory/risk impacts,
  • assist with or approve certain basic AML/ATF and other assigned risk taking and attestations,
  • assist in preparing AML/ATF and other assigned related control documentation,
  • assist with AML/ATF and other assigned reporting to senior management, and
  • as a supplementary role, lead or assist with other business control mandates (e.g. FATCA)
  • other tasks as assigned.

The nature of this role will shift over time as the business mix and structure of BMO Asia changes and grows.

KNOWLEDGE AND SKILLS
a) Knowledge

  • University degree
  • Working knowledge of applicable Bank systems and procedures helpful
  • Knowledge of Microsoft Office Suite
  • Working knowledge of AML strongly preferred helpful

b) Skills

  • Analytical Thinking
  • Problem Solving
  • Organizational Understanding
  • Risk Management
  • Influence
  • Problem Solving
  • Relationship Management
  • Fluency (written/oral) in English and Mandarin required, Cantonese & other Asian languages an asset
  • Demonstrated above average judgment, decisiveness,
  • Excellent verbal and written communication skills.

ACCOUNTABILITIES
A: Business Delivery & Operational Effectiveness
B: Client & Relationship Management
C: Risk Management and Control
D: Change & Innovation

KEY ACCOUNTABILITIES
Business Delivery & Operational Effectiveness
Analyze information related to system or manually generated alerts to identify persons and entities that may be laundering money or funding terrorism, escalating as appropriate for further investigation or reporting in accordance with defined processes and legislation.
Identify unusual activities and behaviors across multiple products, analyzing and assessing information and referring all transactions that may relate to money laundering or terrorist financing for further investigation or reporting as outlined in documented processes and protocols.
Log all incoming referrals/triggers/Unusual Activity Reports, alerts, etc. ensuring all required data is captured completely and accurately.
Risk score all incoming files; where identified medium/high risk customer, completing documentation and EDD review as per AML procedures.
Assimilate all relevant EDD/CDD documentation from the various lines of business.
Follow up for documentation / information if not received in a timely manner.
Communicate with Front Line and lines of business partners and Customer directly (where possible/appropriate) to obtain required information/documentation
Create virtual and physical files collecting and providing assessment of information pertinent to the investigation and (where required) enhanced due diligence.  Provide any additional information/clarification to the colleagues as required to move the enhanced due diligence forward.
Ensure that all files and service requests are logged and reviewed within the timelines; while meeting the daily or monthly targets, ensuring that the quality of the work performed meets the standards prescribed.
Collect and analyze a wide variety of information to provide enhanced due diligence for accounts that have been identified as medium/high risk, acting within established prescribed processes/guidelines set by the AML leadership team to identify and document possible risks specific to this account and preparing files for review.
Conduct a comprehensive review of high risk clients and recommend, assess risks posed to the Bank, and provide a final recommendation to onboard/maintain/demarket client based on assessment and risk of client.
Evaluate options for compliance with regulatory requirements and define and recommend possible solutions/actions to mitigate identified risks.

B. Client & Relationship Management
Act as the first point of contact for the lines of business answering questions and providing subject matter expertise and information to ensure processes and procedures are followed as required.
Provide input into the development of training aids/materials based on gaps identified through interaction with lines of business, to ensure compliance requirements related to the AML/ATF legislation, policies, procedures for high risk accounts are well understood.
Provide guidance to lines of business for dealing with customers who have been identified as medium/high risk accounts.

C. Risk Management and Control     
Control multiple sources of information (e.g. CMCIF, email, fax) to ensure information received is actioned appropriately and responses to various lines of business need to be sent out in a timely manner based on the direction received.
Maintain control of all hard copy files ensuring they are complete and securely stored. Responsible for the document retrieval and storage process in place.
Seek guidance if required from management in order to ensure the smooth operation of this process. Document all information found throughout the investigation, developing and maintaining account files in a manner that will ensure compliance with the AML/TF customer due diligence operating directive and AML procedures.
Ensure problem escalation, mitigation and preventative measures are consistent with regulatory and corporate requirements Complete audits and reviews of files, procedures, systems, etc. as required, ensuring proper controls are in place.
Support the fulfillment of necessary reporting requirements by ensuring accurate documentation, timely disposition and provision of critical information assessment including input to MIS, for analysis and reporting on information from assigned systems for the purpose of analyzing and detecting name matches/irrational or unusual activity, as required.
Advise management of any AML developments and emerging issues gleaned from lines of business during regular interaction to ensure they are well understood and expected impacts are fully considered.
Support effective utilization of AML systems, tools and reports to detect and manage AML by participating in ongoing training to develop and maintain knowledge, skills and capability.
Ensure adherence to all aspects of First Principles, our code of Business Conduct and Ethics, including individual accountability as it relates to potential conflicts of interest, safeguarding of customer information, trading in securities, anti-money laundering, privacy and disclosure of outside business activities.

D. Change & Innovation
Make recommendations to management for the enhancement of AML and other assigned processes.
Maintain an understanding of money laundering and terrorist financing issues, including policies, procedures, regulations, industry best practices, criminal activities and developing trends.
Assist in identifying opportunities to improve processes and procedures and additional training requirements for the group Assist in moving BMO Asia to a Business Process Management (BPM) focus with process insights and participating in re-engineering/BPM efforts Support and assist the AMLRO Office with implementing process changes as necessary (e.g. to improve productivity, improve control, offer better service to customers, launch new products, or comply with new regulations).

AUTHORITIES:  
To deliver on these accountabilities, the incumbent will have the following authorities:

Monitoring Has the authority to examine the work of others to ensure compliance with agreed upon operating requirements Recommend Has the authority to provide recommend for actions to mitigate risk.
Recommend Authority to identify and recommend changes to processes for AML data and document control
Acquittal
Authority to decision/acquit/exclude within guidelines
Escalation Authority to escalate any AML reporting and adjudication issues
Information Access Has authority to use and access confidential information related to customer information, product and financial information

CROSS-FUNCTIONAL RELATIONSHIPS:
This job requires the incumbent to interact with the following groups in BMO Financial Group:

  •  Lines of Business/Relationship Managers/Line Management/Branch Management
  • Technology and Operations
  • Compliance/National AML Compliance Officer
  • Capital Markets AML Office
  • EBC Colleagues

SCOPE AND IMPACT
This role supports the identification and mitigation of AML/ATF risk for BMO Asia.  Penalties for Non-Compliance with the Legislation dealing with Money Laundering offences are severe.  Criminal charges arising from any issues of non-compliance would have a significant and damaging effect on Bank’s image, reputation and shareholder value.

WORKING CONDITIONS:
Sensory Attention: high need to concentrate with one or more of the five senses (e.g. reading/observing, listening, etc.) to identify and decipher information

APPLY FOR THIS JOB

Send your resume and cover letter to Doug.Sibley@bmo.com.