HSBC Group

Business: Risk & Compliance

Open positions:1

Role Title: Assistant Vice President Risk Stewardship – Sanctions GSC’s

Global Career Band: 5

Location (Country / City ): India/Bangalore

Recruiter Name : Geetika Gupta

The Opportunity:

Financial Crime

• The Financial Crime (FC) Function is a Second line of defence (LOD) function that includes ”Risk Stewards” who are independent of the commercial risk-taking activities undertaken by the Group’s businesses (also referred to as “the First LOD” or “FLOD”). The FC Function also operates a set of critical controls on behalf of the FLOD by harnessing intelligence, analytics, technology, detection and investigation. The Risk Stewards are responsible for reviewing and challenging all the activities of the FLOD to ensure that, as “Risk Owners”, they effectively manage the FC risk inherent in, or arising from, the conduct of their activities and for which they are responsible. FC risk is a non-financial risk that includes fraud, money laundering, bribery and corruption, sanctions violations, terrorist financing, proliferation financing, export control violations and tax evasion. The FC function operates in accordance with HSBC Group’s Risk Management Framework (RMF).
• The Assistant Vice President  Risk Stewardship – Sanction role will work with for a team of Sanction risk professionals supporting the Risk stewardship teams across Group / Regions and Markets, in addition to playing an advisory role/influence the direction of the risk discipline to effectively identify and mitigate Financial Crime (FC) risk.
• Sanctions roles are responsible for ensuring HSBC's compliance with trade, economic and/or financial sanctions administered by the U.S. Office of Foreign Assets Control, United Nations, European Union and HM Treasury's Financial Sanctions, protecting the organisation from financial crime. This will involve partnering businesses, developing and implementing strategies, processes, controls and policies and ensuring appropriate training and communications are delivered to HSBC employees.
• The remit of role holder will be to support the Global / Regional FC teams.  

Role holders will carry out activities that will include most of the following, but not limited to:

• Monitor Trade, Economic and Financial Sanctions (including sanctions programs administered by the U.S. Office of Foreign Assets Control, United Nations, European Union and HM Treasury’s Financial Sanctions, (collectively referred to herein as “Sanctions”), and Global RMF to meet legislative and regulatory requirements.
• Assist Global / Regional Sanctions Risk Stewards in providing oversight and management, of all aspects of Financial Crime Risk Sanctions including impact analysis of regulatory changes.
• Collate potential breaches of sanctions from across the business lines & subsidiaries, review reporting made and escalate to Global / Regional `Sanctions Risk Steward
• Stay at the forefront of key regulatory changes to ensure proactive communication with business and implement appropriate policy and framework to manage the changes.
• Participate in and work with relevant local industry bodies and groups in relation to Sanctions related initiatives, trends and proposals.
• Provide advice to business across on risk associated with prospective business, products and service and design mitigation controls and implement strategies as appropriate.
• Managing Breach reporting (Mostly, sanctions policy breach write-up currently by Sanctions team)
• Managing incident escalation and reporting (prepare escalation up to Global / Regional sanctions, core incident write-up including detailing root causes and actions and deep drive analysis and potential read-across reviews will continue to be decisioned by relevant Sanctions team)
• Coordinate governance inputs (e.g., Risk Map, RMM, Risk Committee, FC ExCo, Country/Regional /Global forums), and track NFR Risk Steward Maturity Assessment, RAPID2, IRIS, Helios and Engage.
• Preparing the Global / Regional Sanctions monthly MI reporting.
• Sanctions list management and maintenance of LGE (support any new list/entry to be deployed and maintained via LGE (the “grey list” process)
• Managing EWRA leg work, sanity checks (annual preparation on sanctions data for EWRA including data verification and analytical work on Sanctions inherent and residual risk analysis)
• Preparation of Global / Regional Sanctions ManCo materials and coordination of governance inputs (e.g. risk map, RMM, risk committee, FC ExCo)
• Support the Global / Regional FC Risk Stewards, provide oversight of Sanctions controls to effectively challenge risks or control outcomes through analysis and review of Issue Management, L1 and L2 Controls, Inherent and Residual risks. Ensure overdue issues and actions are communicated to the relevant stakeholders as per guidance
• Perform read across of 2/3 LOD review reports and prepare read across actions for risk stewards for further disbursement. Update summary documents ( eg. Audit Summary matrix ) for Audit reports to ensure themes can be identified
• Set & maintain Global FC Policy ( Liase with Risk Stewards and assist to undertake consultation activities, where relevant, with respect to changes/developments in Group policies/guidance)
• Update the Sanctions guidance documents to ensure consistent application of the Sanctions framework across markets
• Ability to translate MI of existing 1LoD controls into summaries for 2LoD Risk Stewards to highlight potential gaps, enhancements, or expansions to the Bank's overall Sanctions Risk coverage.
• Prepare and design governance packs to facilitate and include the key data elements required to understand the control environment of Sanctions
• Co-ordinate and manage projects
• Support in reviewing the change initiatives driven at the market level
• Monitor issues management from a wide range of sources, including MSII’s, Audit Reports, Assurance reporting and where available, Monitor reviews.
• The monitoring of key controls and 1LoD performance through ‘heat maps’ is an essential ask of the Risk Steward. The role would be directly responsible for the ongoing monitoring, analysis, coordination (with 1LoD) and escalation of risks and failure points as identified by such heatmaps.
• Support with generating of reports which include KPI / KRI metrics and associated trend analysis on a monthly basis
• Oversight and challenge of the use and adoption of NFRO / RMF deliverables and standards to ensure they are embedded and effective across FC
• Support the Global / Regional Sanctions domain in various activties/tasks

What you’ll do:

Principal Accountabilities: key activities and decision-making areas

The following principal accountabilities are aligned to the Financial Crime Services and Processes Model.

Impact on the Business

• Proactive approach to the identification of FC risk change and potential impacts.
• Identify FC Risks in the relevant business and provide necessary assessments and solutions, including establish and implement strategic policies which ensure exposure to current risks and emerging arising risk is managed appropriately.
• Represent FC in relevant governance forums and attend to all internal and regulatory audits and inspections relevant to the business covered.
• Work closely with relevant stakeholders within Group, Regions, Functions (including DBS) and ServCo to provide expertise and support on all financial crime related matters.
• As one of the managers within the FC organization, the incumbent should drive consistency in messaging throughout the organization and building a culture of transparency between FC and 1LOD.
• Support Sanctions risk Projects as SME support (Policy / Procedure, Analytics, Training etc.)

Customer / Stakeholders

• Lead / liaison with relevant stakeholder within Global / Regional Sanctions and relevant teams to provide expertise and support on all FC risk related matters.
• Ensure that appropriate, timely and relevant risk information is provided to stakeholders and Risk Management forums.
• Develop and maintain a strong and professional working relationship with relevant stakeholders within Risk and Compliance, Audit and Finance at Business and Global / Regional levels.

Leadership and Teamwork

• Work closely with Line Manager to provide guidance and support in the management of the team.
• Drive attainment of functional/functional unit results
• Share best practice with teams in the regions and globally.
• Maintain and develop positive and professional working relationships with senior business managers at the Group and Regional levels. Lead by example, demonstrating excellent behaviours in line with HSBC core values.
• Assist in recruitment, retention and development of colleagues and take responsibility for own development.
• Work effectively as part of a team, taking the lead where appropriate and contributing to team output and collaboration.
• Foster a learning agile culture, promoting proactive review of lessons learned.
• Support an inclusive environment that supports diversity and reflects the HSBC brand. Ensures effective and open communication, team building, knowledge sharing, coaching and mentoring not only within the function but to the broader organisation.

Operational Effectiveness and Control

• Focus on aligning the HSBC operating practices with changes in Global FC policy and regulatory risk, and ensure that the FC Risk Framework remains appropriate.
• Resolve any/all identified issues promptly, and escalate concerns to management as appropriate to ensure timely awareness of any material concerns.
• Maintain and observe all HSBC control standards and implement and observe the Global FC Policy, including the timely implementation of recommendations made by internal/external auditors and external regulators.
• Maintain awareness of operational risk within assigned portfolio and minimise the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.
• Leadership over all FC matters and the management of operational risk.
• Ability to clearly identify FC risks and provide necessary analysis, advice, solutions and support.
• Ability to interpret regulatory developments and advise on its impact to business, provision of practical and compliant solutions.
• Ability to deal with Senior Management and Business in a professional and proactive manner.

Management of Risk

• The management of financial crime risks is an integral part of the role profile. This role will continually reassess the operational risks inherent in FC by taking account of changing economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new technology.
• This will be achieved by ensuring all actions take account of the likelihood of financial crime risk occurring and by addressing any areas of concern in conjunction with line management and / or the appropriate department.

Observation of Internal Controls

Managers are accountable for setting the ‘tone at the top’ which underpins the principles of a positive and effective internal control environment. They should exhibit leadership and direction to their teams for establishing and maintaining an effective internal control environment, including the development and management of policies and procedures where appropriate. Managers should also ensure that suitable processes are put in place to review and oversee the internal control environment against those policies.

Local Job Requirements

Major Challenges

• HSBC is an extremely diverse business with significant geographical spread and activities that span a universal banking model, including continuing to innovate to keep abreast of changes in financial services markets globally. Such activity is in an increasingly regulated and complex global environment with often little consistency between laws and regulations in different jurisdictions and regulators taking a far more proactive approach in ensuring local compliance with their requirements and imposing increasingly stringent sanctions for breaches.
• The incumbent is required to ensure the consistent application of the highest risk management standards, notwithstanding the complexities of business operations across regions. The incumbent would identify, plan and implement change programs to ensure that HSBC remains in line with regulatory requirements across the Group.
• This role also needs to operate within a matrix environment, requiring strong leadership skills to collaborate with multiple stakeholders and deliver results. The role holder must be able to influence senior management and articulate clear business reasons for change initiatives, within the scope of this role.
• To drive change in culture with respect to the management of FC Risk, in accordance with the three lines of Defence model. To manage the inter-linked and competing demands of developing, implementing and improving strategic Financial Crime systems and controls on a Group wide basis, while also providing for adequate commercial view and balance.

Role Context

• The role will report to the Vice President Risk Stewardship – Sanctions
• This can involve dealing with major issues for which there is no clear-cut solution whilst still being able to provide judgment and clear direction. Where items of major consequence are involved, engagement with the relevant top-level management will be expected, directly and through collaboration with Vice President Risk Stewardship – Sanctions and Head of FC Risk Stewardship COE, as appropriate.

What you will need to succeed in the role:

• Experience in Financial Crime Risk management advisory or similar Risk function.
• Proficient knowledge of Sanctions risk, Export control breaches, Screening and Payment transparency in the financial services industry.
• Working experience of how controls associated with Sanctions risk mitigate FC Risk and the various underpinning activities.
• Understanding of how controls address the underlying FC Risk and associated aspects forming the overall Risk Management framework.
• Excellent communication and inter-personal skills, with experience of dealing with stakeholders  including the capacity to articulate the case for risk management.
• Experience of interpreting and analysing a large volume of information and / or data and provide succinct summary for management. 
• Ability to lead change, contributing to joining up with the other teams in Risk and Compliance and Business globally
• Ability to work independently on distinct tasks, escalating as appropriate.
• Experience in leading a team / group of individuals is desirable

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You’ll achieve more at HSBC

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