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COMPLIANCE

The Compliance function is a Second line of defence (LOD) function, responsible for reviewing and challenging the activities of the Group’s businesses (also referred to as “the First LOD”) to ensure that they effectively manage as “Risk Owners” the Regulatory and Financial Crime Compliance risks[1] inherent in or arising from the conduct of their activities and for which they are responsible. The Second LOD consists of 'Risk Stewards' who are independent of the commercial risk-taking activities undertaken by the First LOD. The Compliance function is a Risk Steward for a number of non-financial risks in accordance with HSBC Group’s risk framework. 

The VP Compliance Advisory - CMB & GBM , for HBAP INM is an accountable executive responsible and supporting the Head of Compliance Advisory – CMB and GBM in ensuring that HSBC’s operations in HBAP INM CMB and GBM are effective in identifying, managing, and mitigating Regulatory Compliance and Financial Crime risks and ensure timely advice is provided to the business

Principle Responsibilities

 The responsibilities of the VP Compliance Advisory - CMB & GBM India are to:

• Primarily to support CMB & GBM Advisory, to maintain an effective control framework and to ensure compliance with all relevant external laws & regulations, internal codes and policies and good market practices with primary focus on CMB and GBM area.
• Articulate the Regulatory Compliance and Financial Crime risks for HBAP INM CMB & GBM.
• Provide advisory services to HBAP INM CMB & GBM business to ensure clear understanding of compliance risk exposure with respect to clients, transactions, and products.
• Manage the relationship with relevant regulators on behalf of HBAP INM CMB & GBM.
• Be responsible for second line governance of Regulatory Compliance and Financial Crime risks exposures, providing analysis, reporting and governance to HBAP INM CMB & GBM that is independent of the first line of defence, thereby maintaining an objective assessment of risk exposure.
• To exercise risk steward challenge, act as independent trusted advisory in governance forums, issue management, fostering a compliance culture and optimizing relations with risk owners and control owners.
• Assist the senior management of HBAP INM CMB & GBM, the leadership of the Compliance function, and other colleagues on all material compliance related matters. 
• Represents the Compliance agenda up to the highest levels of the Group’s governance, including being an attendee (as required) at the HBAP INM CMB & GBM governance forums (and related sub-committees) to report on progress and issues in relation to the operational effectiveness of HSBC’s policies, processes, systems and controls in countering Regulatory Compliance and Financial Crime risks.
• Support Head of Compliance Advisory – CMB and GBM in establishing guiding principles and strategic operational objectives, owning budgeting, and managing costs, headcount, and resources to ensure that the teams are fit for purpose and that the delivery of its critical services to the Group is both effective and cost-efficient.

Impact on the Business

• Support in overseeing the critical Compliance policies and systems that impact HBAP INM CMB & GBM and ensure that the Group’s exposure to Regulatory Compliance and Financial Crime risks is managed in a commercially sensitive, practical, and cost-effective manner.
• Provide advice and support on Regulatory Compliance and Financial Crime risks to senior management, Compliance, and other colleagues.

Customer / Stakeholders

• Reporting to Head of Compliance Advisory – CMB and GBM as relevant on Regulatory Compliance and Financial Crime risks matters.  
• Ensure that senior management are appropriately advised of all material Compliance related matters relating to HBAP INM CMB & GBM.
• Manage and foster a strong relationship with all relevant regulators in relation to the activities of HBAP INM CMB & GBM and ensure timely disclosure of relevant information, in relation to financial crime, and regulatory compliance related matters.
• Ensure that positive relationships are maintained with other external stakeholders relevant to the Compliance agenda.

Leadership and Teamwork

• Maintain and develop positive and professional working relationships with senior business managers and Compliance colleagues at the Group level and those in other Regions and Businesses.
• Support Head of Compliance Advisory – CMB and GBM in creating an environment for the delivery of consistent performance measurement, training, career management and succession planning across the CMB & GBM Compliance Advisory for HBAP INM Compliance capability.
• Support Head of Compliance Advisory – CMB and GBM in establishing a strategy for the sharing of Regulatory Compliance and Financial Crime risks related compliance knowledge and best practice across HBAP INM CMB & GBM and the wider Compliance Function and Group

Operational Effectiveness and Control

• Create a framework for the effective risk-based monitoring of the implementation of Regulatory Compliance and Financial Crime risks related policies and controls across HBAP INM CMB & GBM.
• Agree and oversee the implementation, embedding and monitoring of the adherence to the Compliance FIM in HBAP INM CMB & GBM.
• Monitor and assess the resourcing, costs and spend of the HBAP INM CMB & GBM Compliance Advisory team.

Management of Risk

This will be achieved by ensuring all actions take account of the likelihood of Compliance 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 that 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 VP Compliance Advisory - CMB & GBM for HBAP INM, as a member of the Compliance function 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 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 Regulators have high expectations and is likely to come under scrutiny as part of any major regulatory investigation.

• Minimum Graduation or as required for the role, whichever is higher
• Significant experience as a regulator, or a senior compliance manager across all areas of Compliance risk within a global firm, in the financial services industry. 
• Detailed and extensive knowledge of the HSBC Group structure, its business and personnel, and HSBC’s corporate culture.
• Significant leadership experience and an experienced strategic thinker.
• Excellent communication and inter-personal skills, with experience of dealing with executives at all levels.
• Ability to develop practical, cost effective solutions to complex global issues.
• A legal or formal accountancy qualification or professional background in a relevant risk or audit discipline.

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