Responsible for overall regulatory compliance within MashreqBank - New York branch.
Ensure implementation / compliance to various regulations and guidelines that are issued by local regulatory authorities (including compliance to various regulations that relate to anti money laundering and terrorism financing).
liaise with IBG-Compliance and execute / implement the requirements according to the decision at HO and after the approval of AML Committee.
Implement HO guidelines / procedure at branch level after approval of AML Committee, in liaison with IBG Compliance.
Support branch operations by providing compliant solutions to regulatory requirements and intervene where necessary to stop a transaction / process / business proposal and seek Country Manager and IBG Compliance guidance, if necessary.
and bank is not investigated, charged, fined or publicly castigated by any regulatory authority.
Ensure monitoring of transactions in respect to various local regulatory / internal lists.
Periodically conduct risk based review of customer account activity from AML perspective (transaction patterning / structuring etc) in comparison with expected activity.
Periodically conduct risk based review of trade transactions to monitor compliance with BSA / AML and Anti-boycott laws as per BSA / AML, OFAC and Anti-boycott Manuals.
Responsible to perform the function of Manager Compliance and Money Laundering Reporting Officer in his absence.
Responsible for initiating money laundering related investigations and drawing conclusion and initiating Suspicious Activity Report to the regulatory authorities, if approved by AML Committee.
Evaluate, train and motivate branch and centralized processing staff to enhance their skills and knowledge of anti money laundering, compliance and regulatory matters.
Document and record details of trainings provided. (training(s) to centralized processing staff should be arranged through IBG Compliance who will be responsible to impart such trainings upon request of MBNY compliance).
Conduct special investigation on the request from Head Office, Mashreq Bank branches and Other Regulatory Bodies in liaison with IBG-
Compliance. Inform IBG Compliance, unless it is prohibited by local laws.
Ensure that AML & Compliance related SOPs / processes are followed at branch & centralized processing department and are kept up to date in respect of applicable regulations.
Responsible for maintaining branch Anti Money Laundering Handbook for Staff and for updating the same as legislation and regulations change, with the approval of AML Committee.
Responsible for updating / maintaining policies that ensure compliance to various other local regulations (policies such as Abandoned Property Policy, OFAC Manual, Assets Maintenance and Pledge of Assets Policy, Right to Financial Privacy and Consumer Data Protection , Physical Security and Safety Manual, Anti-
Boycott Policy, Federal Election Campaign Act Compliance Policy, Bank's Bribery Act Policy, Foreign Corrupt Practices Act Compliance Policy, Record Retention Policy, Denied Persons Policy).
Ensure that all internal audit reports, those are conducted in the branch relating to Regulatory Compliance are retained, reviewed and that an action plan on the audit observations is properly executed / regularized within the deadlines.
This function needs to examine and evaluate the adequacy and effectiveness of internal controls / audit inline with local regulatory requirements to ensure ARCG audits covers all the functions of the branch and meet all the control requirements of various legislations and regulatory guidelines.
in case of need matter should be escalated to IBG-Compliance.
Ensure that all statutory reports and / or request for information received from regulators are handled in timely manner.
Assist ARCG Fraud Investigation Dept in matter that relate to fraud investigation.
Perform additional tasks / Conduct Compliance related investigations as required / determined by IBG-Compliance / HO-Compliance / ARCG, identifying any issues / concerns and report findings / recommendations for corrective action as required.
Any other duties which may be entrusted by the IBG Compliance from time to time.
NOTE : Some of the regulatory circulars and requests (For example National Security Letters and FinCEN 314(a) requests / list) will not be shared with those parties who are not subject to USA regulations due to restrictions and sensitivity / confidentiality of the information contained in those circulars / requests.
This observation should be read with all those compliance functions where MBNY is supposed to share and disseminate local regulatory information to Head Office and other related offices..
Key Result Area
Assist Manager Compliance / Branch MLRO, IBG Compliance and Branch Management in attaining compliance objectives.
Maintain ongoing awareness / current knowledge of all applicable internal / external regulatory requirements identify issues that could impact the branch / bank and escalate any serious issues / breaches / violations to IBG-
Compliance and Branch Management ; develop / monitor action plans for its closure in liaison with Country Manager and IBG-Compliance.
Review new regulatory legislations; promptly communicate all regulatory notices / circulars to all concerned areas, provide interpretations if necessary to Branch management and IBG-
Compliance; develop / monitor action plans towards its implementation.
Ensure continuing compliance of branch processes / systems / products -review branch procedures / SOPs / service level agreements etc.
inline with various regulatory legislations & guidelines; where deficiencies are detected, make recommendations to Country Manager and IBG Compliance in order to bring procedures / processes in line with the requirements.
Manage Regulatory Examinations; ensure implementation / regularization of inspection / audit recommendations and observations with the deadline(s).
Keep Country Manager / IBG Compliance updated.
Respond to queries that are sought by local Regulatory Authorities / Law Enforcement Agencies / Head Office & Overseas branches relating to local laws / regulations, in timely manner with complete and accurate information.
Arrange to receive all local regulatory circulars and notices (from Compliance perspective) by subscribing to them; ensure that these are made available to every employee at the branch.
Update Country Manager / IBG-Compliance.
Submit monthly Compliance-MIS to IBG-Compliance; ensure capturing of compliance related issues those are resolved and pending.
Ensure branch compliance to local AML / CFT regulations where applicable maintain and update the local AML Policy Manual’ with the approval of AML Committee and IBG-
Compliance; ensure that every employee at the branch and centralized operations personnel at HO, reads and understands the banks / branch AML policy.
Ensure submission of staff AML declarations’ to this affect on an annual basis.
Provide all new staff at NY Branch with full training (within 3 months of joining) and provide staff with regular updates on the money laundering regulations and requirements.
Implement AML monitoring procedures & controls at branch level; ensure all customer accounts / activities are covered under the monitoring process.
In case where alerts / profiles generated from GiftsEDD System are reviewed by Compliance staff, perform sample review i.
e. minimum 15% of the reports to obtain assurance that the staff analysts are adequately researching and investigating the cases, and document his / her findings.
Undertake review of suspicious transaction(s) that get noticed or that has been brought to the attention of compliance; discuss unusual activity / transactions with relationship managers and report to AML Committee raise SAR to the relevant regulatory authority, if approved by AML Committee.
Supervise / monitor / approve daily filtering of all payments and swift messages in respect of terrorist and criminal names appearing in US Government Lists / Watch List.
Provide support to Head Office Auditors from compliance perspective and Regulatory Examiners while their visit the branch for inspection.
Ensure that all transactional referrals and account documentation checking and risk rating of Countries and Customers is handled in a timely manner.
Actively participate in applications systems and product development and provide value added recommendations to ensure that all systems and products in the branch have appropriate internal controls related to Regulatory Compliance to ensure efficient customer service, compliance of local laws / regulations and protect the assets of the bank.
Surface risks proactively and in a timely manner and keep a vigilant eye on branch activities to identify any unusual activity.
Knowledge, Skills and Experience
Graduate with 7 10 years banking experience.
Good understanding of local regulatory rules and regulations.
Knowledge and Understanding AML Law and various Banking legislations.
Computer literate and good command over spoken and written English
Audit Fraud and Compliance Group
Jun 7, 2018