Anti-Corruption & Financial Crime Lead

Reporting to the Head of Financial Crime Compliance UK, the role entails providing Anti-corruption and Financial Crime related advice relating to requirements under the UK Corporate Criminal Offences (UK Bribery Act, UK Criminal Finances Act and UK

Economic Crime & Corporate Transparency Act); primarily pertaining to the Anti Bribery & Corruption (ABC), Anti-Fraud and the Anti-Facilitation of Tax Evasion (ATEF) risk pillars. Working closely with the first line of defence Business Areas, Compliance teams who support this activity as well as other units in the first line of defence. The role also supports the broader Financial Crime programmes on matters related to AML/CTF and Sanctions policy and advisory where relevant.

Good working knowledge of providing support on Anti-corruption and Financial Crime issues as well as a thorough understanding of best practice and risk mitigation under relevant statutory Guidance, and the practical application of this advice in a global and local context. The requirement of the role will be to lead on anti-corruption activities and support broader financial crime policy and advisory activities where relevant.

The key responsibilities of the role will include:

• Define risk appetite statements for the ABC, Fraud and ATEF Anti-Corruption Compliance Risk Pillars. Working alongside the financial crime programme team and providing input into the other risk pillars including AML/CTF and Sanctions.
• Lead and take an active role in developing and maintaining the ABC, Fraud and ATEF function by advising on the continual update and enhancement of relevant policies and proce-dures and local addenda impacting those pillars in line with the regulatory obligations, statutory guidance or relevant risk events.
• Lead on second line compliance activities covering; business partners/vendors, associated persons, gifts & entertainment and mandatory time away (MTA).
• Oversight of appropriate on-boarding and periodic risk-based Due Diligence risks from an ABC, Fraud and ATEF.
• Ensuring the implementation of Commerzbank’s ABC, Fraud and ATEF legal obligations register and application of robust operational controls.
• Ensuring the oversight and continued update of MI relating to ABC, Fraud and ATEF processes undertaken by Commerzbank London Branch.
• Oversight of appropriate policies, procedures, systems, and controls relevant to those pillars
• Take reasonable steps to establish and maintain adequate arrangements for awareness and training in Financial Crime matters (in conjunction with other staff). The role will require delivery of Fraud & Financial Crime Training to all staff, including targeted training to the second line of defence and/or first line of de-fence where appropriate.
• Day to day issues affecting a financial crime team of a global corporate and investment bank; including governance, policy, risk assessment, procedures, operations and reporting, external reporting and feedback into the overall financial crime risk management process.
• Source, review, disseminate and act on national and international findings as required by FCA and/or the law enforcement authorities.
• Ensuring Governance arrangements with regards to relationships of any outsourced AML/CTF activities.
• Delivery of mandatory external reporting e.g. PSD2, APP Fraud, Annual MLRO report, REP-CRIM, Annual Report of Blocked Property.
• Successful applicant expected to be conversant in all Financial Crime Compliance Risk Pillars however will lead/ act as the SME for the ABC, Fraud andATEF.
• In collaboration with other functions, produce the Bank’s annual UK Modern Slavery Act statement

Key activities:

• Provide Anti-corruption & Financial Crime (with a specific focus on ABC, Fraud and ATEF) related advice and support on a proactive and reactive basis in respect of the specified entities and other Commerzbank entities as required, working closely with the business line Compliance teams who support this activity and the Client Lifecycle Manage-ment Team.
• Liaise and coordinate with other compliance staff in Commerzbank offices to facilitate harmonisation of global stand-ards and policies across the group and maximise flow of useful information.
• Be a key member of the second line of defence team with regards to financial crime and fraud prevention and provide support to the Head of Financial Crime – London branch.
• Knowledge of UK regulatory and legislative requirements and appreciation and awareness of industry best practise and standards. Knowledge of German UK regulatory and legislative requirements is desirable.
• Ability to clearly identify and articulate risk appetite to determine mitigating factors and potential controls to mitigate and manage residual risk.
• Production of an ABC, Fraud and ATEF risk assessment – for the organisation, its businesses, the jurisdictions, cus-tomers, products and delivery channels.
• Ability to articulate impact of changes to policies, standards, addenda and relevant procedures including ability to pro-vide training on relevant changes.
• Strong working knowledge, understanding and practical aspects of an effective financial crime risk man-agement framework.
• When required, maintain involvement in industry working parties, groups and external forums on ABC, Fraud and ATEF to keep Commerzbank practice in line with good industry practice in this area.
• Provide ABC, Fraud and ATEF and other financial crime related input on group and general is-sues as required and promote effective financial crime compliance throughout Commerzbank. This will in-clude supporting more junior or less experienced members of staff as well as communicating upcoming changes to key business units and acting as a subject matter expert for all Compliance Risk Pillars in or-der to support all advisory enquiries.
• It would be beneficial to have practical knowledge of Investment Banking products.
• Contribute to the bank’s EWRA (Enterprise-wide risk assessment) and any other projects as required.
• Oversight of Compliance Risk Pillars. When required, assist Group representatives and representatives from the au-thorities and regulator during audits/reviews, etc.
• Train and oversee resources with the P&A Team dedicated to ABC, Fraud and ATEF programme tasks.

Key requirements:

• Experience in Compliance or a relevant field, broad second line of defence Financial Crime experience de-sired with a strong focus on advisory services.
• Detailed knowledge and understanding of local and international regulatory frameworks.
• Ability to lead teams in a manner that encourages them to work efficiently with an attention to detail in their general everyday activities.
• Exceptional oral, written, and interpersonal communication skills with the ability to communicate complex information accurately, clearly and quickly to all levels.
• Knowledge of corporate company structures and weaknesses from ABC, Fraud and ATEF perspective.
• Proven experience of well-rounded investment banking knowledge.
• Supervisory experience.
• Familiarity in dealing with law enforcement and regulators, an existing network would be an asset.
• Project management skills and experience.
• ACAMS certified or equivalent BSA/AML certification preferred.
• Vocational training, university degree or similar, preferably in Banking, or Law Specialist or Enforcement knowledge (work experience, further qualification).

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