I am responsible, in my capacity as CFCC Advisory, CCIB Client Coverage for supporting the Head, CFCC Advisory, CCIB, Nigeria & West Africa in managing all regulatory and CFCC risks relating to the Corporate, Commercial & Institutional Banking (“CCIB”) business in Africa and Middle East (“AME”) and aligning this to the vision and strategy of the function, the Enterprise Risk Management Framework (“ERMF”), and delegation of authority documents where relevant.
I have first line responsibility for the implementation of Conduct, Compliance and FCC policies and procedures for CCIB processes to the extent the processes have been identified as owned by the CFCC function, in line with the Group’s process universe as set out in the Group Operational Risk Framework, including activities within the processes owned by the CFCC function which are hubbed or outsourced.
Insofar as they relate to CCIB Client Coverage Products, Channels and Segments, conduct, financial crime and compliance, I am responsible for providing details of developments giving rise to a material risk that serious regulatory breaches or breaches of risk tolerances (as agreed by the Board from time to time) may occur and notifying any such breaches to:
Head, CFCC Advisory, CCIB, Nigeria & West Africa
Head, CFCC, Nigeria & West Africa
Head, FCC, Nigeria & West Africa
Heads of CCIB & Head of CM Nigeria and West Africa Respectively
My responsibility does not encompass the operation of information technology systems used to implement any policies and procedures, which is the responsibility of the Group Chief Information Officer and does not encompass fraud or cyber related matters.
For the purposes of this Job Description, FM also includes Mergers & Acqusition
I am responsible:To help the Group meet its commitment of being "Here for Good" by building a sustainable framework that places Compliance, Conduct and FCC best practice standards, at the forefront of the Group's agenda. As an independent 2nd Line Risk Control function, to execute the relevant aspects of the CFCC Principal Risk Types Frameworks (“PRTFs”) through robust independent risk control and the provision of specialist advice and constructive challenge in a manner proportionate to the nature, scale and complexity of the FM businesses. For the evaluation and assessment of the effectiveness of the Group’s Conduct, Financial Crime and Compliance Risk Frameworks. To proactively support and challenge the FM businesses and supporting functions to exhibit appropriate conduct, comply with regulatory and compliance requirements and strive to achieve fair outcome for the CCIB Client Coverage clients. For maintaining independence, deliveing timely responses, and timely escalation of risks and issues where the management tolerance of the firm is exceeded. For maintaining constructive and effective stakeholder relationships with the relevant business and supporting functions, and to assist the Head, CFCC Advisory, CCIB, Nigeria & West Africa; to interface with and support all key stakeholders. For supporting the management of regulatory relationships with all of the Group’s regulators, whose rules the Group is subject to.
StrategyContribute materially towards the implementation of the vision, strategy, and direction of CCIB Client Coverage CFCC Advisory teams, consistent with Regional Head, CFCC Advisory, CCIB Client Coverage’s vision and strategy for the Regional CCIB Client Coverage CFCC team and the strategy of the CFCC function as a whole, and in support of the Bank’s strategic direction and growth aspirations. Continue to improve the Group’s approach towards reducing regulatory and financial crime risks throughout the Regional CCIB Client Coverage client lifecycle (from on-boarding to off-boarding) in order to protect the reputation of the Group and to avoid significant financial loss. Provide consistent support to colleagues with responsibilities for CCIB Client Coverage (of which all references shall also include products/services such as Lending, Mergers & Acquisitions and ESG Advisory), including highlighting key areas of pan-geographical focus. Drive an increased awareness of CCIB Client Coverage technical and strategic knowledge in regions and countries to sharpen focus on how local regulatory reform impacts the client segments.
BusinessSupport Resolution of competing requirements between regulations specific to CCIB Client Coverage ( between AML regulations and data privacy/bank secrecy or information security regulations). Develop a comprehensive foundational understanding of the business model and strategy in order to provide substantive required oversight support and challenge in order to enable appropriate and sustainable CFCC outcomes. Build and maintain an effective and constructive relationship with all key business and functional stakeholders that is based on trust, capability and integrity, providing timely, responsive and quality advice and guidance to enable the business and functions to meet/ achieve their strategic tactical objectives. Provide robust challenge to senior management and all relevant business stakeholders where activities are outside risk tolerance/ appetite, escalating as necessary, until appropriate oversight and ownership is achieved including actions and plans to address any remedial action needed to come back within risk tolerance/ appetite. Provide and communicate timely CFCC related advice, analysis (and challenge when appropriate) in relation to CCIB Client Coverage including product design through to post sale reviews / assessments, new business initiatives, bespoke projects, remedial activities (including nature, scale and rigour of past business reviews), and transactional advice. Support the maintenance of global CFCC standards in accordance with standards set by senior management. Support the maintenance and refresh of relevant CFCC frameworks applicable to CCIB Client Coverage. Support the implementation of the SPOC-COE model. This includes (but not limited to): taking ownership of incoming queries by not handing them off, taking a leading role in actively becoming the go-to person for the business/function and ensuring advice provided is consistent throughout CFCC Advisory in relation to CCIB Client Coverage.
ProcessesDrive the governance and oversight over the implementation of CFCC related policies and procedures with respect to CCIB Client Coverage (to enable compliance with such policies and procedures). Support efforts to establish and maintain effective processes (including training, advice and support) to ensure that policies and standards to address CFCC risk are effectively implemented across CCIB Client Coverage. Support the provision of second line challenge to processes owned by CCIB Client Coverage, including (but not limited to) specific Risk Framework Owner oversight of Complaint Handling, Client Off-Boarding, Know Your Distributors, Bad Debt Sales, Enterprise Appropriateness, Regulatory On-Boarding, CDD, AML Surveillance, and Customer Screening in CCIB Client Coverage. Develop and maintain effective policies/processes/DOIs (including training, advice and support) to address CFCC risks across CCIB Client Coverage, aligning with relevant regulatory requirements. Provide support and challenge to the relevant Business stakeholders COO teams to ensure that they establish and monitor appropriate processes for compliance with CFCC policies and standards (including meeting regulatory obligations and maintaining high standards of conduct).
People & TalentRole model and assist the Regional Head of CFCC Advisory, CCIB Client Coverage to build the appropriate culture and values. Set appropriate tone and expectations within their team and work in collaboration with risk and control partners. Contribute to promoting and embedding a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm. Contribute to instilling an environment where forward planning, prioritisation, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm. Assist in the provision of ongoing training and development to ensure that team members are competent, suitably skilled and qualified for their roles, ensuring that they have effective supervision in place to mitigate any risks. Provide constructive developmental feedback at business, function, country and individual level as appropriate, on CFCC matters. Contribute materially towards the migration of skill, knowledge, best practice and lesson learned across the network between CFCC Advisory and Centre of Expertise colleagues especially in relation to legal/regulatory risks and compliance with relevant regulations and internal policies/standards as they pertain to CCIB Client Coverage. Assist CCIB Client Coverage CFCC teams in regions and countries to understand the objectives/deliverables Contribute to the agenda of, and engagement within, the CCIB Client Coverage CFCC functional meetings, and promote adherence to the stakeholder map, ensuring efficient alignment of business and function. Collaborate with training teams to input into training curriculum to support closing of capability gaps and to meet the training needs of CCIB Client Coverage.
Risk ManagementSupport efforts to anticipate horizon risks that may have a significant impact on the Bank and develop effective strategies to mitigate such horizon risks including global standards for conduct of business. Support efforts to ensure the effective management of CFCC matters, management of regulatory issues that have a significant impact on the Bank and support relevant stakeholders to respond to regulatory questions. In the event of serious regulatory breaches, or where risk tolerances have been breached, ensure appropriate and timely escalation within the Group and that actions are taken quickly to remediate and/or activities are ceased. Ensure proactive and timely identification, assessment, advice and dissemination of evolving regulatory changes/practices and associated risks impacting CCIB Client Coverage. Collaborate with other CFCC teams to support a programme for conduct, financial crime and compliance monitoring, surveillance and/or assurance for CCIB Client Coverage. Implement and contribute to the management of MI / trackers across all aspects of their coverage and responsibility to ensure all issues and matters relating to CCIB Client Coverage are tracked, followed, regularly assessed and reported on including oversight of risk acceptance and/or mitigating action plans, identification and management of high-risk clients or specific country reviews relating to CCIB Client Coverage. Play an integral role in the effective management of CFCC Advisory matters, and in collaboration with the rest of the CFCC team, effectively manage regulatory issues that have a significant impact on the Group including but not limited to conflicts of interest, cross –border and onshore/offshore transactional support and control and Conflict of Interest (COI) Compliance teams). Assist and work closely with the Group Shared Investigation Services team in relation to investigations concerning CCIB Client Coverage. Provide robust challenge to and maintain oversight of risk acceptance and/or mitigating action plans relating to CCIB Client Coverage where CFCC is the RFO. Taking a leading role in the proposal of control improvements, enhancements and simplifications relating to CCIB Client Coverage processes that manage CFCC risk, where appropriate. Collaborate with relevant business and CFCC stakeholders to work towards holistic risk management across client segments / products risks. Assist the Cluster Head of CFCC Advisory, CCIB, Nigeria & West Africa to provide reports to relevant risk and control committees and management group on key CFCC risks and issues pertaining to CCIB Client Coverage. Provide intelligence (to internal forums) on specific clients, client-types and emerging risk typologies, and to support the calibration of bank’s Risk Methodologies (including aggregate client risk, product risk and country risk assessments).
GovernanceDrive the identification and escalation of potential risks and issues to senior management through appropriate governance channels and the Quality Assurance framework. Support the management of end-to-end life cycle of audit, assurance and regulatory reviews, in relation to CCIB Client Coverage, including tracking, remediation and preparing lessons learned from such reviews. Develop control effectiveness and efficiency improvements and simplifications where appropriate. Within the Group's overall ERMF, develop appropriate risk-based compliance frameworks for identifying, assessing, managing, monitoring, mitigating and reporting compliance and financial crime risks across CCIB Client Coverage. . Develop or assist in developing and recommend (for approval by the relevant Risk Committee and/or individuals), appropriate compliance policies and standards to manage CFCC risk in CCIB Client Coverage.
Regulatory & Business ConductDisplay exemplary conduct and live by the Group's Values and Code of Conduct. Effectively and collaboratively identify, escalate, mitigate and resolve risk and CFCC matters. Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct, across the Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct. Contributing to drive the CCIB Client Coverage CFCC Advisory teams to achieve the outcomes set out in the Bank’s Conduct Principles: Fair Outcomes for Clients; Effective Financial Markets; Financial Crime Compliance; and The Right Environment.
Project/Change managementAssist from a CFCC perspective in the review of new business requirements and provision of solutions for CCIB Client Coverage where required. Support key change programmes and projects for CFCC Advisory, CCIB Client Coverage.
Key stakeholdersHead, CFCC, Nigeria & West Africa Head, FCC, Nigeria & West Africa Regional Head, CFCC Advisory, CCIB, AME Global Head, CFCC Advisory, CCIB Heads of Business segments GS, CB & FI Head of Client Management / IMO, Nigeria & West Africa Other Risks and Control Functional Heads (Risk, Audit, etc)
Role Specific Technical CompetenciesBusiness Ethics Cross-functional Collaboration Effective Communications Industry Knowledge Internal Controls Risk Management
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