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Background

Investigative Reporting is one of four investigative teams within FCI (Financial Crime Investigation). It is responsible for high volume investigations, including cases generated under automated transaction monitoring procedures, true match cases generated from name screening alerts, referrals from Fraud Operations, as well as cases resulting from Financial Crime – Unusual Activity Reporting (FC-UARs), production/court orders and other referrals where FCI Triage has assessed that the case is appropriate for referral to Investigative Reporting.  Transaction monitoring generated cases includes Dynamic Risk Assessment (DRA) cases, where implemented, or scheduled to be implemented as well as classic transaction monitoring cases.

Investigative Reporting prepares reports or appropriate closing summaries for all investigations conducted and prepares and files ‘suspicious transaction reports (STRs) on such investigations, where warranted. Investigative Reporting is responsible for ensuring that findings of financial crime risk are shared with relevant risk owners and/or risk stewards for investigations conducted by Investigative Reporting and making any cross border referrals to other Investigative Reporting teams, where appropriate.  Designated team members or points of contact located in-market are responsible for final decisioning, in coordination with the MLRO and filing of STRs.

Role Overview

The Investigator role is responsible for conducting financial crime investigations, in accordance with the Investigative Reporting Instructions, to assess where potential financial crime risk is present, assess appropriate referrals for action, as well as referral of the case, if warranted, to designated Investigators for regulatory filing decisions and filing. The Investigator in this role will generally work on cases (DRA or non-DRA)

Principal Accountabilities: key activities and decision making areas

·       Responsible for conducting effective and timely investigations into assigned cases in accordance with agreed standard for reporting requirements and service level agreements. These cases may include:

o   Cases generated by transaction monitoring systems, including DRA;

o   FC-Unusual Activity Report raised from various parts of the bank, and referred, as appropriate, by Triage to Investigative Reporting;

o   Escalated cases identified by true matches to screening lists by Name Screening teams;

o   Cross-border referrals; and

o   Escalated cases from Fraud Operations.

·   Work independently to complete assigned tasks and submit high quality investigation reports or closing summaries within the established process SLAs as per the standards agreed.

·   Determine information and documentary evidence needed to support the case decision and to ensure adequate record of such in an approved case management system.

·   Conclude each case investigations, and make appropriate recommendations based upon the assessment, which may include referral to the MLRO or designated in-market Investigators as to whether a STR should be filed or in consultation with the     respective manager, make referrals to other Investigations teams (Complex Investigations or Major Investigations).

·  Seek advice from Subject Matter Experts (e.g. AB&C, Sanctions Advisory and Tax Transparency etc.), where appropriate.

  Identify and complete appropriate referrals for action, including but not limited to, recommendations for exit, and KYC/CDD refresh referrals.

  Demonstrate continuous development of investigative best practice, skills and experience whilst in role.

Impact on the Business/Function across the region

·       Appropriate pro-active use, where appropriate, of media reports and relevant tools, including websites to gather information and identify customers of HSBC involved in financial crime, including money laundering and terrorism.

·       Produce high quality case reports and summaries, including a quality narrative and recommendation as to whether or not a STR is appropriate with onward escalation for disclosure to the relevant authorities in accordance with procedural standards.

·       Identify appropriate referrals for action, and effecting of such in accordance with procedural standards.

·       Process a proportionate number of cases to the agreed procedural standards required and within agreed service level agreements.

·      Ensure appropriate consideration given to each case as to content and quality of content/narrative.

     Determine whether the case warrants escalation to other Investigations teams or requires input from other SMEs, taking care to evaluate appropriately against relevant escalation criteria.

Customers / Stakeholders

·       Provide precise and concise questions and requests of relevant supporting documents during Request for Information (RFI) process to address specific concerns while maintaining customer satisfaction.

·       Appropriate assessment with the context of all gather information of responses to RFIs, seeking where appropriate, supplementary information.

·       Demonstrate comprehensive knowledge and risk-based decisioning on conducting in depth investigations.

·       Issues / problems are effectively investigated and resolved or are appropriately referred to appropriate stakeholders with recommendations.

      Demonstrate ways to improve investigations and increase productivity.

Leadership & Teamwork

·       Ensure compliance with Regulatory, Bank Policy and Principles. Maintain records, and update case histories.

·       Work effectively and professionally with team mates and colleagues across Investigations and the wider organization.

      Build on the knowledge of latest financial crime trends. Actively seeks out, shares and encourages the adoption of best practice within and across teams.

Operational Effectiveness & Control

·       Ensure performance meets the requirements of any relevant service level agreements and at all times, adheres to, Market, Regional, Group and Regulatory policies.

      Support regulatory, audit and assurance reviews as required.

Management of Risk

The jobholder will ensure that alignment to the requirements of the role by ensuring that they attest to reading and understanding the Investigation Manual, and the Investigative Reporting Instructions, along with ensuring completion of any mandatory and or required training, within the timeframe determined by the function and or Learning & Development.

 Where required through the role, they will undertake training in line with the expectations of the role.

 Any concerns must be escalated through line management as soon as they become apparent.

Observation of Internal Controls

The jobholder will also adhere to and be able to demonstrate adherence to internal controls and to all relevant procedures, keeping appropriate records and, where necessary, by the timely implementation of internal and external audit points, including issues raised by external regulators.

The jobholder will implement the Regulatory and Bank’s compliance policy by containing compliance risk in liaison with Group and regional Compliance functions. The term ‘compliance’ embraces all relevant financial services laws, rules and codes with which the business has to comply.

Major Challenges

The job holder must keep up to date with the latest financial crime trends and techniques as the technology is getting more sophisticated by the day and any breaches in reporting could lead to reputation loss for the bank. 

Ensure suspicious activity is referred to the appropriate designated investigators for STR filing decisions in a timely manner and in accordance with the applicable regulatory requirement for STR filings.

Ensure that decisions to report to the authorities, or not, can be justified by documenting high quality, rationale, supported by investigative work and recorded findings.

Role Dimensions

The job holder is part of a team consisting of between 8 to 12 other investigators under a team manager.

Knowledge/Qualifications

Essential

Knowledge of financial crime risk indicators.

Good spoken and written communication skills with the ability to draft written summaries and communicate conclusions effectively in a clear, concise and professional manner.

Good critical thinking and analytical skills. Ability to make informed risk-based decisions and support with robust supporting rationale.

Experience of analysing transaction data, along with customer data and external research finding, to assess whether activity is unusual and poses possible financial crime risk.

Collaborative working style with colleagues and broader stakeholders within a cross-border and LoB matrix organisation.

A motivated self-starter who has the ability to work effectively alone and under pressure.

Capable of picking up, and applying, new ideas/concepts quickly with positive 'can do' attitude.

Desirable

Prior experience of TM Operations

ACAMS or International Compliance Association (ICA) certificate/diploma, or similar qualifications.

Additional information

Mandatory to successfully complete Anti-Money Laundering and Sanctions training and post-course assessment, as required.

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Issued by The Hongkong and Shanghai Banking Corporation Limited, India