Job description
Business : Risk and Compliance, Financial Crime
Open Role : 1
Role Title : Head of Customer Monitoring
GCB : 3
Location : Bangalore, Hyderabad, Kolkata
Recruiter : Jui Banerjee
Why Join us ?
If you’re looking for further opportunities to develop your career, take the next step in fulfilling your potential right here at HSBC.
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 (Financial Crime) 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 Opportunity:
The Head of Customer Monitoring is the Control owner responsible for FC Detection outcomes leveraging the DRA capabilities and Customer Transaction Monitoring. The role holder is focused on and responsible for design and delivery of the Customer Monitoring DRA and strategic rules strategy. The role is a key risk management role with a targeted remit and responsibilities including, but not limited to:
- Contribute to the global strategic direction for Customer Monitoring to protect the Group from the risk of transacting in contravention of regulatory requirements and / or Group Policies. This accountability includes providing oversight of advanced capabilities within the DRA or other strategic technology to assemble a collection of techniques that yield valuable insights and drive identification and mitigation of the FC risks facing the Group, now and in the future.
- Management of discrete Customer Monitoring sub-value stream with accountability for the design, measurement, prioritisation and implementation of technical and business activities as they relate to Customer Monitoring DRA. Leadership of cross-functional experts (pods) from analytics, technology, transformation and product management disciplines in the execution of FC risk management programmes that directly impact Customer Monitoring DRA outcomes.
- Enabling future state thinking to ensure enterprise-wide applications of successful Customer Monitoring outcomes and the development of strategic technologies and significant investment cases to support the firm’s response to FC risk at all levels.
- Continually improving risk effectiveness and efficiency while meeting cost expectations and navigating competing priorities. Accountability for providing effective oversight and active challenge for poor, inefficient or excessive controls, related tasks and behaviours.
- Acting as a control owner as defined in the Operational Risk Policy and maintaining accountability for the key controls and oversight of the associated procedures within the function.
- The level of governance and control of analytical models is increasing across the bank. The role holder will be accountable for ensuring that the model governance and oversight framework is adhered to, and will take accountability for the specific model risk roles allocated to the position and value stream.
- The role holder will continually reassess the effectiveness of the model risk controls given the dynamic nature of models and FC, while also liaising with the Model Risk Stewards and Independent Model Review (IMR) as appropriate.
- Responsibility for ensuring that upstream functional and data providers understand and meet their obligations to enable effective, efficient and resilient Customer Monitoring services.
- Ensuring that Customer Monitoring services are resilient, secure and operate in accordance with HSBC ethical principles and relevant data privacy standards.
- Providing the support and coordination necessary to manage the FC Function’s response to critical incidents related to Customer Monitoring (DRA) outcomes with significant FC implications (i.e., crisis response) requiring a coordinated response across Global FC sub-functions, global businesses, regions, or countries.
- To stay at the forefront of key regulatory changes, particularly where relevant to Customer Monitoring (DRA) techniques and outcomes, to ensure proactive information sharing and communication contribute to appropriate policy and framework changes.
What you'll do?
The following principal accountabilities are aligned to the FC Services and Processes Model.
Impact on the Business:
- Develop and maintain strong relationships with key internal stakeholders across Global functions, Global businesses, Digital Business Services (DBS), Regions, Countries and Markets.
- Develop and maintain a strong and professional working relationship with Senior Management of Risk, Audit and Finance at Business, Group and Regional levels.
- Support external relationships with key public sector partners and peers. Contribute towards the strategic direction and oversight of the firm’s participation in initiatives with key members of Group, public sector and peers to share information on FC risks and their impact on the control framework.
- Identify, facilitate selection and manage vendors as appropriate to maximize cost-efficient delivery whilst promoting strategic partnership.
- Lead or liaise with relevant stakeholders to provide expertise and support on all FC Customer Monitoring (DRA) related matters.
- Ensure appropriate timely and relevant risk information is provided to appropriate governance fora. Manage the sharing of information and creation of feedback loops across the firm to continuously adapt and improve our FC controls and support the business in their first line responsibilities. Lead on the coordination of responses to critical incidents as appropriate.
Leadership and Teamwork:
- Support the establishment of a strategy for the sharing of Customer Monitoring (DRA) related developments and best practice across the wider FC Function
- Provide leadership to, and develop, expertise across advanced capabilities of screening, monitoring, analytics, product management, transformation and technology with a view to continuously evolve the Customer Monitoring (DRA). Proactively drive the value stream approach aligned to detection outcomes to deliver a seamless integration of cross-functional expertise. Provide directional leadership to members of the value stream for which the role holder does not have direct functional reporting lines (e.g., Information Technology staff)
- Maintain and develop positive and professional working relationships with senior business leaders, Risk and Compliance colleagues and FC Risk Stewards at Group, Regional and Market / Entity level
- Create an environment for the delivery of consistent performance measurement, training, career management and succession planning across the function
- Create an engaged, high performing team by demonstrating inclusive leadership practices, delivering an enhanced employee experience for all employee journeys and proactively building the capability of own team and others
- Foster a learning agile culture, promoting proactive review of lessons learned.
- Ensure development activities are a core priority and enable all team members to take reasonable time for learning and developmental activities including taking a hands-on approach to coaching with regular & productive use of Personal Development Plans and appropriate follow up
- Cultivate 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:
- Drive the articulation and embedding of framework, policies, procedures, and controls as they relate to Customer Monitoring (DRA). Ensure that these are updated for changes in regulation and impacts on business
- 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 relevant policies, including the timely implementation of recommendations made by internal / external auditors and external regulators
- Maintain awareness of operational risk within the value stream and minimise the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting
- Establish manual and automated technical processes to ensure and evidence rigorous adherence to Group policies and management of operational risk
- Develop and present options to implement controls whilst retaining full benefit from investment in systems
- Maintain sound understanding of key threats and system vulnerabilities and engage proactively with risk stewards to mitigate the impact of compromise
Management of Risk:
- The role holder will continually reassess the operational risks associated with the role and inherent in the business, taking account of changing FC threats, geopolitical, economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructuring, and the impact of new technology.
- The role holder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organization.
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.
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.
It is the role of the Head of Customer Monitoring, as a key senior member of the FC Detection team to assist the Group in achieving a balance between the demands of regulators, external bodies and governmental initiatives and the Group’s shareholders and customers in enacting FC compliance; being alive to the political, management, regulatory and reputational implications of a particular decision and courses of action at a global level; assisting executive management in the development of controls and systems and influencing the way in which the business is conducted in order to manage these risks, meeting Group risk appetite. The increased focus on individual liability for senior managers, particularly Risk Heads, makes it increasingly important for the Group to be able to evidence adequate systems and controls. The role is one where regulatory authority have high expectations and is likely to come under scrutiny as part of any major regulatory investigation.
Role Context:
The role holder is required to manage and lead the FC Detection Customer Monitoring (DRA) value stream and establish the procedures of the Group in managing these risks. 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 and governance bodies will be expected, directly and through collaboration with the Group Head of FC Detection. The nature of the role requires close working contact with senior executives across the Group. Appropriate presence in external stakeholder fora may also be necessary.
Requirements
What you will need to succeed in this role?
- Significant experience within a regulatory, investigative or intelligence agency, or as a senior compliance or technology manager within a global firm, in the financial services industry.
- Deep expertise and experience in using technology to monitor customers to detect FC at a strategic level.
- An understanding of how data science, advanced analytics methodologies, and technological tools are deployed to monitor customers, including how these tools are used to improve alert volumes and risk coverage.
- Significant Experience in leading large complex transformation programmes.
- A technical understanding of how machine learning and AI techniques are deployed to monitor customers.
- Successful track record in leadership and influencing is essential, including the application of this skill in areas outside their direct span of control.
- A background or understanding of operational risk is desirable.
- Track record of resilience and confident challenge when dealing with senior stakeholders to influence change without direct responsibility for resources or budget.
- Experience of dealing with regulatory matters and confident interaction with Regulators, Internal Audit and Assurance.
- Experience of creating, leading and motivating a team within a matrixed environment preferred, including the management of international teams.
- Leadership experience and an experienced strategic thinker.
- Excellent communication and inter-personal skills, with experience of dealing with executives at all levels.
- Role model leadership, communication and influencing skills, with experience of dealing with senior managers including the capacity to articulate the case for risk management in the language of business.
- Ability to develop practical, cost-effective solutions to what are often complex global issues.
- Ability to lead change, coordinating with other teams globally.
- Ability to interpret and analyse a large volume of information and / or data and provide succinct summary for senior management.
- Ability to prioritise conflicting demands and problem solve in a dynamic environment.
Link to Candidate User Guide:
You’ll achieve more at HSBC
HSBC is an equal opportunity employer committed to building a culture where all employees are valued, respected and opinions count. We take pride in providing a workplace that fosters continuous professional development, flexible working and, opportunities to grow within an inclusive and diverse environment. We encourage applications from all suitably qualified persons irrespective of, but not limited to, their gender or genetic information, sexual orientation, ethnicity, religion, social status, medical care leave requirements, political affiliation, people with disabilities, color, national origin, veteran status, etc., We consider all applications based on merit and suitability to the role.”
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Nom du recruteur
Jui Banerjee
E-mail du recruteur
jui.banerjee@hsbc.co.in