HSBC Group

Business: Risk & Compliance

Open positions: 1

Role Title: VP, FC Control - Customer Monitoring GSC’s

Global Career Band: 4

Location (Country / City ): Bangalore

Recruiter Name : Priyanka Ochani

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”). The Financial Crime Function also operates a set of critical controls on behalf of the Group’s businesses (FLOD) by harnessing intelligence, analytics, technology, detection and investigation. The Risk Stewards are responsible for reviewing and challenging all the activities of the First LOD to ensure that, as “Risk Owners”, they effectively manage the financial crime risk inherent in, or arising from, the conduct of their activities and for which they are responsible. Financial crime 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 Financial Crime function operates in accordance with HSBC Group’s Risk Management Framework (RMF).
• The Senior Control Manager - Customer Monitoring has to work closely with Head of Customer Monitoring Control with responsibility for the Customer DRA and other TM Controls and providing leadership and coordination of all matters relating to ongoing Internal Audits, Compliance Assurance, and Independent Model Reviews. The role is a key risk management role with a targeted remit and responsibilities including, but not limited to:

Responsibility for the overall management of the DRA and other TM controls including:

• Responsibility for the ongoing review of the design of the controls, assess the implementation, appropriately assess Design, Operation, and Control Effectiveness.
• Responsibility for Monitor the effectiveness of the controls over time, ensuring monitoring plans are completed in Helios on time and conduct Continuous Monitoring
• Accountability for promptly escalating control weaknesses and gaps to the Risk Owner(s), including how and when they will be fixed. - Escalate events, near misses, control failures to the impacted Risk Owner and/or Business Service Owner (where applicable)
• Responsibly for continued adherence to the NFR Change Framework for Live TM controls.
• Responsibility for the model risk control framework as it relates to Customer Monitoring ensuring a strong working relationship with Model Risk Management
• Responsible for co-ordination and management of all second- and third-line reviews including Independent Model Reviews as they relate to the Customer Monitoring Sub Value Steam
• Responsible for providing oversight and coordination of issue management to ensure adherance to committed management action plan closure dates

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

• Apply judgement on the criticality and operational prioritisation with a view to influence both short term tactical changes and longer-term strategic direction of the Customer Monitoring controls
• Membership and participation in governance fora as relevant across the wider Financial Crime Detection Value Stream and Global Businesses, Regions and Markets

Customer / Stakeholders

• Develop and maintain strong relationships with key internal stakeholders across Global functions, Global businesses, Digital Business Services (DBS), regions, and countries
• Devekio and maintain strong working relationship with Model Risk Management
• Develop and maintain a strong and professional working relationship with senior management of Risk, and Audit
• 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 financial crime risks and their impact on the control framework
• 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 financial crime controls and support the business in their first line responsibilities. Lead on the coordination of responses to critical incidents as appropriate

Leadership and Teamwork

• Provide leadership to, and develop, expertise across the Customer Monitoring Sub value Stream on controls management,  Model Risk Management and second and third line review requirements.
• Maintain and develop positive and professional working relationships with senior business leaders, Risk and Compliance colleagues, Group Internal Audit and Financial Crime Risk Stewards at Group, Regional and Market / Entity level
• 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.

Operational Effectiveness and Control

• Drive the articulation and embedding of framework, policies, procedures, and controls as they relate to the Control framework. 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 financial crime 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 that 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. It is the role of the Head of Control Framework, as a key senior member of the Financial Crime 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 financial crime 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 authorities have high expectations and is likely to come under scrutiny as part of any major regulatory investigation.

Role Context

• The role holder has senior accountability for ensuring the Customer Monitoring controls remain effective and pro-active management of all second- and third-lines reviews of the controls are effectively supported. 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 Head of Customer Monitoring Sub Value Stream.

What you will need to succeed in the role:

Certifications, Qualifications and Experience

• Deep expertise and experience in using technology to detect financial crime at a strategic level
• An understanding of how technological tools are deployed to detect financial crime, inlcuding how these tools are used to improve alert volumes and risk coverage
• A good understanding of the HSBC Risk Management Framework, and a deep knowledge of the Risk and Control environment and processes within Group Financial Crime
• Experience in project management and product ownership in a complex global environment
• An understanding of model risk, the required controls and how models, machine learning and AI techniques are deployed to improve control operations
• Experience of dealing with Second and Third Line Review teams
• 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
• Some experience of dealing with regulatory matters and confident interaction with Regulators
• Experience of creating, leading and motivating a team
• Experience of working 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

Skills

• 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 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

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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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