• Client has been in Malaysia for a long time and is a solid well known bank situated at the heart of the city center.
• This positions reports to the Senior Business Advisor
• The AFCO Function is responsible for assisting the Head of Regulation, Compliance and Anti-Financial Crime in AML, CTF, Sanctions & Embargoes, Anti-Fraud & Investigations (AFI), ABC activities in the jurisdiction. Where ABC or AFI headcount is not present in the location, the responsibility is delegated to the respective regional team. This ensures that all relevant AFC policies, procedures, systems and controls are implemented effectively, all AFC-relevant legal, regulatory and DB Group requirements are met and any AFC-related risks are appropriately addressed and mitigated.
• The AFCO is also responsible for the identification, assessment, advice on, monitoring, control and reporting on the AFC laws, rules and standards relevant to the DB activities in their respective jurisdiction,
• The AFCO is the direct point of contact for DB staff in AFC matters, in particular in terms of whistle-blowing, employee reliability or concerns raised in a confidential environment when improper or illegal AFC related activities are suspected.
Position Specific Responsibilities and Accountabilities
• The AFCO has decision-making authority over the Business on AFC related matters.
• The AFCO has unrestricted access to all information, data, records and systems in the Bank he/she deems necessary to fulfil its function.
• Advising on and ensuring implementation of AFC policies and procedures whereas involvement in ABC and AFI policies will be assisted by the respective regional team.
• Advising on the impact of new AFC related internal and external rules and ensuring that local guidelines and procedures are in line and reflect German and local laws /regulations. Escalate exceptions to the Country AFC Officer, Head of Regulation, Compliance and Anti-Financial Crime and Regional Head of AFC.
• Assessing the conformity of internal policies and procedures, systems and controls with relevant regulatory obligations and DB Group standards.
• Being primary point of contact for AFC matters with competent regulatory, law enforcement or other public authorities in their jurisdiction, and in the local ABC and AFI matters, in conjunction with the respective regional heads.
• Reporting and liaising with SEA AML manager, Regional Head of AFC, Country AFC Officer, Head of Regulation, Compliance and Anti-Financial CrimeCountry AFC Officer and other AFC Senior Management to ensure appropriate reporting and escalation of issues and/or incidents.
• Contributing to DB AFC Function as a whole by sharing knowledge and best practices with AFC Officers of the other Businesses and entities and other AFCOs. Contribute to the development of AFC methodologies by cooperating with other disciplines like Compliance, Legal, Audit and Operational Risk Management.
• Ensuring timely delivery of the local AFC Risk Assessment in the country leveraging off regional assessments performed for ABC and AFI topics.
• Providing AFC advice in the change management process including but not limited to the New Product Approval (NPA) and Vendor Risk Management (VRM) Process.
• Helping maintain an AFC compliance staff awareness culture by providing appropriate training to staff and arranging training by other regional leads for Sanctions & Embargoes, ABC and AFI. Oversight of local Training and ensure that AFC Training requirements are met in conjunction with the aforementioned leads.
• Developing and maintaining the AFC related Internal Control Framework under advice from Country AFC Officer, Head of Regulation, Compliance and Anti-Financial Crime, and Regional AFC Risks & Controls to ensure adequate monitoring and control measures are implemented, report on any findings and advise management on remedial actions to take.
• Complying with the requirements set by the AFC Global Controls Programme. Develop and carry out adequate controls to ensure that all applicable legal and regulatory AFC requirements are being adhered to in their jurisdiction.
AML: Maintaining especially an adequate Internal Control Framework for Unusual and/or
Suspicious Transactions in terms of organization, administration systems and controls to
ensure properly and timely detection, investigation and reporting of unusual and/or suspicious
transactions or activities to competent authorities in compliance with applicable rules.
• Implementing adequate monitoring – research /surveillance tools.
• Discharging the responsibilities of AFC as set out under global KYC policies for divisions present in the jurisdiction.
• Deciding on new or existing clients that are escalated, or decide to escalate further.
• Tracking and following-up on the conditions that have been imposed as part of the KYC approval.
• Following-up with the Business on status of Regular Reviews and obtain relevant MIS from the Business.
• Sanctions: Monitoring local regulatory sanctions developments and notifying relevant changes and specifications to the Head of Regulation, Compliance and Anti-Financial Crime, Country AFC Officer and Regional Head of Sanctions.
• Discharging the responsibilities of the Group Embargo Office locally as set out in the Group Embargo Policy and in the Special Risk Country Policy, in particular, ensuring implementation of applicable sanctions requirements on a country level.
• Anti-Fraud: AFCO locally must assume and promote AFC’s responsibility for anti-fraud in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional AFI teams.
• The AFCO must refer all fraud matters to the relevant Regional Head of AF&I who will provide support in delivery against these anti-fraud responsibilities remotely from a regional level.
• Anti-Bribery & Corruption: AFCO locally must assume and promote AFC’s responsibility for anti-bribery & corruption in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional ABC teams.
• The AFCO must refer all bribery and corruption matters to the relevant Regional Head of ABC who will provide support in delivery against these anti-bribery & corruption responsibilities remotely from a regional level.
• Ensuring that AFC Employee Reliability Requirements are met.
• Ensuring that local record keeping processes are in alignment with the AFC related legislative, regulatory and internal requirements.
• Providing input for MI reports requested by Global AFC, Head of Regulation, Compliance and Anti-Financial Crime, Country AFC Officer or the AFC reporting function.
• Implementing any Governance related controls, processes and procedures as directed by the AFC Governance function
• Actively supports the business strategy, plans and values, contributing to the achievement of a high performance culture
• Takes ownership for own career management, seeking opportunities for continuous development of personal capability and improved performance contribution
• Acts as a role model for new employees, providing help and support to facilitate early integration and assimilation of their new environment
• Supports tough people decisions to ensure people performance is aligned with organisation imperatives and needs. Addresses individual performance issues, where necessary, to drive for high performance
• 4+ years relevant experience.
• Work experience in a regulator or financial institution.
• Degree qualified
• Relevant AML or related certifications (desirable)
• Excellent proficiency in written and verbal English required. Ability in other languages is an advantage.