Sr Specialist, Compliance & Control - Deputy MLRO
BNY MellonLuxembourgUpdate time: July 9,2021
Job Description
Role Overview: The Compliance function, as defined by the Luxembourg regulator, is an independent function whose objective is to identify and assess the compliance risk of an institution, as well as to assist senior management in managing and monitoring this risk. It contributes to the good functioning of the institutions, by controlling activities and/or functions under their direct responsibility. Thereby, compliance is a regular control associated with an on-going and close monitoring of the institution’s operations and related risks. The purpose of the Compliance function is to organise, coordinate and structure compliance-related controls already carried out under the terms of other regulations, but which are currently often spread over several different organisational levels. The Compliance function aims at protecting the institution from any prejudice that might result from the failure to comply with the rules in force and at contributing to the efficient management of ensuing risks. The Compliance Manager will Act as Deputy MLRO for the Luxembourg legal banking entities as required Lead Financial Crime initiatives within The Bank of New York Mellon SA/NV, Luxembourg Branch Identify and analyse key AML regulatory developments Provide oversight and guidance in all areas relating to Financial Crime. Key Responsibilities: Predominantly (approx. 80%) of working hours allocated to Financial Crime related tasks within the BNYM Compliance pillars of Advisory, Monitoring and PRG (Policies, Regulatory Change and Governance): Provide financial crime advice and guidance to business / operational staff, as required Keep up to date with Luxembourg financial crime related developments and issues Responsible for review of relevant financial crime draft legislation / regulations / circulars/ guidance papers and co-ordinate a response, gap analysis and work with the business on implementation where appropriate. Deal with relevant regulatory correspondence both to and from regulatory authorities, as part of regular reporting requirements, and on issues arising in respect of financial crime. Participate in monthly EMEA Anti-Money Laundering Oversight Committee (EAMLOC), including presentation of items as appropriate for Luxembourg, when required Assist the business to prepare and review all relevant submissions for EAMLOC in advance of monthly meeting Attend relevant Luxembourg forums and ensure oversight and tracking of financial crime issues raised Provide monthly management information for inclusion in Luxembourg governance bodies ( i.e. the BNY M Lux Risk forum and the BNYM Lux Branch management meeting) Prepare all regulatory reports on Financial Crime related aspects as required, e.g. to the CSSF, CNPD, FIU etc. Assist businesses in ensuring that AML issues are addressed in the event of changes to systems, client take-on, acquisitions and any other relevant projects Receive Suspicious Activity Reports, assess them and submit notifications/disclosures to external authorities as necessary; Coordinate, advise on and review relevant business AML and ABC Risk Assessments Review and approve relevant business procedures / manuals, including business updates following regulatory change. Provide support and advice to businesses on procedural implications and implementation issues Oversee all outsourced Financial Crime related activities including: review and clearance of surveillance alerts, sanctions clearance, KYC outsourced to the AML Due Diligence Team and conduct sampling in relation to all outsourced activities Coordinate and conduct the annual financial crime monitoring program for the Luxembourg branch, including review and tracking of action items Oversee training and awareness for Luxembourg branch staff and assist with the development of relevant training programs as necessary To assist the MLRO in the execution of his duties to ensure that BNY Mellon is able to effectively manage its operational risks and compliance with Luxembourg Data Protection & Privacy regulations on an on-going basis. In addition (approx. 20% of working hours), non-Financial Crime related Compliance tasks within the BNYM Compliance pillars of Advisory, Monitoring and PRG (Policies, Regulatory Change and Governance): Stay current with core regulatory developments which may affect the Luxembourg legal entities and advise management on their implications; Draft policies for the approval of the relevant bodies with the aim of respecting applicable laws, regulations and internal rules; Act as advisor on compliance queries from employees; Assist in the development and deliverance of appropriate compliance training; Provide help to establish and maintain departmental procedures regarding compliance requirements; Be the primary contact for external authorities (regulators, local FIU, external auditors, …) on compliance matters; Undertake appropriate levels of monitoring, utilizing a risk-based plan, to assess the level of compliance being attained by the business; Assess regulatory risks of business developments, new products/services and major projects, and advice management of the implications thereof. Governance Responsibilities: Contribute to the effective governance of the EMEA region. Play an active role in regional committees and local boards, offering constructive challenge and helping to support the Committee/Board fulfil its role and responsibilities for those they are a member. Where the jobholder acts as a Chair of a Board/Committee, ensure the Board/Committee is effective in all aspects of its role, facilitate and encourage informed and constructive debate on key issues and ensure that members receive relevant management information in an accurate, timely and clear form. Help to ensure that a strong governance culture is embedded within the region, that issues are escalated and cascaded appropriately and that key risks are identified, discussed and mitigated. Build a good understanding of the EMEA governance framework, including escalation requirements, and ensure there is clear, appropriate and evidenced apportionment of responsibilities amongst staff members for whom the jobholder has management responsibility. Generic Staff Responsibilities: Comply with all BNY Mellon corporate policies and procedures, including HR policies and procedures, applicable to BNY Mellon Alert management including the Chief Risk Officer and / or the EMEA Chief Risk Officer immediately of any significant changes to business risks and internal control effectiveness. Notify management and/or the Chief Compliance and Ethics Officer and Head of International Compliance immediately on discovery of any material regulatory breach. Comply with all Security and Health & Safety policies and procedures operating within the business. Qualifications Values: Passion for Excellence - We get it done. We strive to be extraordinary. Integrity - We do what is right, always. We challenge each other – even when it is uncomfortable. Strength in Diversity - We seek out who is missing and help everyone feel included. We invest in each other’s success. Courage to Lead - We take the risks necessary to lead. We grow and move on from failures. Core Competencies: Global Acumen - Developing and incorporating an understanding of the competitive global business environment as well as an awareness of economic, social and political trends that impact the organization’s global strategy Establishing Strategic Direction - Establishing and committing to a long-range course of action to accomplish a long-range goal or vision after analyzing factual information and assumptions taking into consideration resources, constraints and organizational values Developing Strategic Relationships - Using appropriate interpersonal styles and communication methods to influence, collaborate and build effective relationships with business partners (e.g., peers, functional partners, external vendors and alliance partners) Building Organisational Talent - Attracting, developing and retaining talented individuals. Providing timely coaching, guidance and feedback to help others maximize their potential and meet key accountabilities. Using appropriate methods and interpersonal styles to develop, motivate and guide a team toward successful outcomes and attainment of business objectives Change Leadership - Continuously seeking (or encouraging others to seek) opportunities for different and innovative approaches to addressing organizational problems and opportunities Client Orientation - Cultivating strategic client relationships and ensuring that the client perspective is the driving force behind all value-added business activities Driving Execution - Translating strategy into operational reality. Breaking down strategic priorities or business initiatives into key tasks and identifying accountabilities. Aligning communication, people, culture, processes, resources and systems to ensure effective implementation and delivery of required results BNY Mellon is an Equal Employment Opportunity Employer. Our ambition is to build the best global team – one that is representative and inclusive of the diverse talent, clients and communities we work with and serve – and to empower our team to do their best work. We support wellbeing and a balanced life, and offer a range of family-friendly, inclusive employment policies and employee forums. Primary Location: Luxembourg-Luxembourg-Luxembourg Job: Risk Internal Jobcode: 85161 Organization: Compliance-HR06015 Requisition Number: 2111496

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