Immediate Manager: Asia Head of Enterprise Business Control and Anti-Money Laundering
Next Level Manager: Chief Operating Officer, (COO) Asia
Banking Group/Department: Corporate Areas, Capital Markets, Wealth Management
Lo Location: Shanghai, Hong Kong, Singapore
Date: April 2015
Accountable to assist the lines of business (LOBs) to design, maintain, improve, and monitor execution of Anti-Money Laundering (AML) risk and control processes for Capital Markets, Private Client Group, and Personal and Commercial operating groups in assigned areas within BMO Asia to ensure the Bank provides excellent customer experience, works with optimal efficiency, and ensures risk taking is within our risk appetite.
Leads a team of AML professionals to delivery services and manage risk. Acquires and balances resources, sets performance targets, holds employees accountable for performance, oversees and approves overtime, and develops staff.
As the Anti-Money Laundering Reporting Officer (AMLRO) Designate’s senior delegate for Capital Markets in the assigned jurisdiction (and other selected LOBs) and a senior manager in the AMLRO Designate for Asia’s team, contribute to delivering excellent service to our customers while ensuring the following specific accountabilities are met with respect to the assigned jurisdiction and Asia (more details of the accountabilities are found in Appendix B of the Enterprise AML Program Manual) along with additional accountabilities assigned from time-to-time by the processes described in the Manual.
- Control Framework. Establish, operate and maintain anti-money laundering, anti-terrorist financing and sanctions measures (collectively, “AML”) procedures, risk and control frameworks for the LOB/LE(s), including implementing effective controls, in accordance with the AML Corporate Policy and the AML Enterprise Program Manual.
- Strategy and Change Management. Advise the CAMLO of LOB/LE products, strategies, Initiatives and relevant jurisdictions of operation.
- Training. Develop, establish and operate risk-based training for the LOB/LE(s) in consultation with the CAMLO.
- Assessments. Inform inherent risk assessments and conduct ongoing control self-assessments for the lines of business.
- Knowledge. Maintain detailed knowledge of applicable legislative requirements.
- AML Program Issues. Identify, report and remediate issues respecting the AML Enterprise Program.
- Monitoring and Reporting. Monitor the AML Program compliance outcomes of controls and report information to the CAMLO respecting control outcomes, compliance gaps, monitoring results and other information respecting the AML Program as required.
- Regulatory Reviews. Collaborate with and ensure the CAMLO is engaged in the execution of AML reviews including Corporate Audits and regulatory examinations of their LOB/LE(s), including coordinating responses to regulator enquiries pertaining to the LOB/LE(s).
Accountable to act as the day-to-day LOB escalation point for AML compliance matters, to clarify requirements with the CAMLO Office and local Compliance as applicable, and to provide risk oversight. Working with LOBs, the incumbent will enable each operating group’s compliance with Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) requirements. The incumbent will:
- design and implement solutions to new AML/ATF regulatory or policy requirements,
- lead projects related to AML/ATF changes,
- create and maintain AML/ATF related procedures,
- create and deliver training programs,
- track and resolve AML/ATF issues related to AML/ATF,
- review new products and initiatives for AML impacts,
- approve certain AML/ATF risk taking,
- directly prepare AML/ATF related control documentation and attestations,
- create AML/ATF reporting to senior management
Business Delivery and Operational Effectiveness
Act as primary liaison with the Operating Group Anti Money Laundering Reporting Officers (AMLROs), the Office of the Chief AML Officer (CAMLO), and local Compliance, the incumbent:
- will be the individual to whom information will be provided on applicable laws, regulations, and AML Program policy requirements on behalf of the Asia LOBs;
- ensure that all operations that are required in order to comply with the AML Program, including appropriate controls required for such activities, are implemented within the LOBs and properly documented via Operating Group policies or otherwise;
- monitor the status of the AML Program respecting the Operating Groups on a regular basis, including the operation of controls.
- Communicate and report to Asia Senior Management of the Operating Groups, the AMLROs, the CAMLO, and local Compliance, on any issues of potential non-compliance, deficiency of controls, or issues the incumbent considers relevant, on a timely basis;
- as applicable, assist the operating group AMLRO, CAMLO, and/or Compliance with information supporting regulator reporting.
- Establish an action plan with defined timelines to close any identified gaps, reporting progress to Asia Senior Management, the AMLROs, the CAMLO, and BMO ChinaCo Compliance, on a regular basis;
- advise the AMLROs and the CAMLO of any significant changes in initiatives, products, delivery channels, customer types, geographies and operational procedures to ensure they are adequately addressed by the AML Program, including, for example, of any expansion of business, office location, services, products or customers to other jurisdictions, through the Investment Decision Process/New Product Approval Process or otherwise.
- Develop, track and follow-up on specific project or implementation deliverables
- With the LOBs carry out the planning, preparation and maintenance of project timelines
- As appropriate, participate in the creation of project documentation, requirements, and updates, as well as creation and consolidation of project reports
- Partner with the LOBs and technology in the maintenance of and/or migration of client AML reference data
- Coordination and, as appropriate, liaise directly with project stakeholders and participants including: LOBs , technology & operations groups, AMLROs, AML Compliance Office, and Corporate compliance
- Contribute to team leadership and motivation, and obtain a high level of co-operation and contribution from team members
- Contribute to and/or carry out various project administration tasks, including meeting coordination, communications releases and maintenance of project tracking logs (i.e. Issues, Change Control, etc.)
- Maintain knowledge of applicable LOB policies and procedures
- Work with the LOBs in the review and development of AML/ATF and Know Your Customer policies and procedures/guidelines in line with regulatory requirements, Bank standards, external benchmarks, and best practices
- Staying current on AML/ATF practices of other Asia banks relative to the areas in scope
- Assist the Lines of Businesses (LOBs) in the development of practices to close gaps identified through the above
- Assist in identification of controls and measures that provide early warning of potential failure to meet AML/ATF risk management objectives
- Monitor the ongoing effectiveness of AML/ATF solutions as the business and environment evolve and change, identifying exposures, gaps and/or trends and making adjustments to address
- Participate in the adjudication of cases or alerts advised by the Bank’s AML Compliance Office and/or China Compliance for watch list management and electronic transaction monitoring, and engaging the businesses when necessary
- Assist the LOBs with unusual activity reporting per applicable processes
- Track progress and outstanding items for incumbent’s follow-up
- Escalate to the AMLROs issues applicable to or impacting performance of the function
Risk Management and Control
- Assist in completion and coordination of AML/ATF Risk Assessment process
- Assist in quarterly reporting to the AML Compliance Office on behalf of the AMLROs
- Complete annual Fraud Risk Assessments
- Handle suspected fraud cases
- Maintain effective relationships with LOB contacts, AMLROs, the AML and local Compliance Office(s), LOB AML Office(s) and functional groups
Change and Innovation
- Partner with the stakeholders on the improvement of operational methods and workflows by identifying, designing, recommending and aiding in the implementation of new processes and process improvements
DECISION-MAKING AUTHORITY / RECOMMENDATION
- AML Risk Approval and Exceptional Approval authority
- Process change control
- Process design
- Group process alignments
- Approval of local variations
- Workload prioritization
- Program structure
- Prioritization of work areas
- Business unit changes
Knowledge & Skills
- University degree or college diploma, preferably in business, law or related
- CAMS designation or in process
- 3-5 years of relevant AML experience in a financial institution
- 5-10 years of overall experience in financial institution
- In-depth knowledge of applicable AML regulatory requirements and practices
- Strong experience with technology solution implementation
- Strong knowledge and understanding of capital markets/investment banking, private client group, and to a lesser extent retail banking businesses
- Knowledge of compliance and risk management practices
- Fluent in Mandarin Chinese and English; other languages an asset
- Highly accurate and detail oriented
- Excellent at organizing information
- Strong analytical and issue/risk identification and escalation, with ability to identify and consider cross impacts, proven critical thinking
- Strong interpersonal skills used within a demanding team environment and in client interaction
- Strong partnering abilities
- Ability to manage high level security access in a professional and ethical manner
- Strong oral and written communication skills
- Good presentation skills
- Highly proficient with Word, Excel, PowerPoint, and adept and learning new applications/systems
- Works independently with appreciation for team work
- Proactive and results oriented
- Ability to manage deliverables
- Ability to communicate and interact with others to achieve deliverables
- Ability to manage high level security access in a professional and ethical manner
- Experience in finance or accounting an asset
The role could involve travel to BMO’s various offices in Asia and offices in North America.