Position: Senior Manager FCC Sanctions
Location: Burnaby, BC
Description: Reporting to the Head of Financial Crime Compliance (FCC) Sanctions, the Senior Manager FCC Sanctions will implement the Trade, Economic and Financial Sanctions and global risk management framework to meet legislative and regulatory requirements within Canada.
This individual will participate in the review and investigation of potential breaches of sanctions from across the Region, reviewing the reporting made, and escalating where appropriate to the Head of Sanctions. The individual will be responsible for monitoring legislation and policies, and risk assessment.
Impact on the Business
- Write, maintain and keep current the HSBC Canada Sanctions Policy including any applicable guidance ensuring it complies with the Global Sanctions policy and local regulatory requirements and abides by sanctions programs administered by Canadian Department of Foreign Affairs under the United Nations Act, Special Economic Measures Act, the Export and Import Permits Act, the Canadian Criminal Code, the U.S. Office of Foreign Assets Control, United Nations, European Union and Treasury’s Financial Sanctions.
- Provide sanctions related guidance on escalated payments, investigations, customer retention etc.
- Identify, assess, oversee and communicate all requirements relating to legal guidance and sanctions evasion trends in relation to risks presented through HSBC’s business activities across the Region.
- Support and facilitate a strategic coordination and implementation of an effective Sanctions controls framework within the Region.
- Assist with ensuring that the Group’s regional exposure to regulatory and reputational risks is managed, in a commercially sensitive, practical and cost effective manner.
- Discharge the relevant accountabilities as set out in the Group FCC standards framework.
- Assist with managing and leading any required remedial action, in assigned area, of all material FCC sanctions issues involving the Region that arise to ensure effective implementation through internal and external reviews.
- In conjunction with Legal, identifying the need for and preparing licencing request.
- Managing global standards within the Region and strategic policies which ensure FCC Sanctions exposure to current risks and emerging arising risk is managed appropriately.
- Implement, as required, Group sanctions policies and systems within the Region that ensure that business exposure to financial crime and reputational risks is managed, in a practical and effective manner, including efficient and reasonable deployment of resources and an understanding of the business operations and needs.
Customers / Stakeholders
- Liaison with relevant stakeholder within Global Business and Functional teams within the Region to provide expertise and support on all Financial Crime Sanctions related matters
- Support the Head of Sanctions and Assistant Chief AML Officer in the provision of reports on Regional Sanctions issues.
- Ensure that the Head of Sanctions and Assistant Chief AML Officer are appropriately advised of material Sanctions issues.
- Where applicable, ensure that the Group’s interests are externally represented and professional and positive relationships are fostered at a Regional level.
Leadership & Teamwork
- Work effectively with regional Head of Sanctions, Assistant Chief AML Officer and other FCC heads to ensure consistency across the FCC functions.
- Maintain and develop positive and professional working relationships with senior business managers at the Region/ Business line levels.
- Foster positive and professional working relationships within FCC and other senior managers throughout the Group.
- Support Head of Sanctions and Assistant Chief AML Officer.
- Promote an environment that supports diversity and reflects the HSBC brand.
Operational Effectiveness & Control
- Provide regional solutions to complex Sanctions issues/initiatives in an ever changing, high-risk environment.
- Ensure all GSM, FIMs, BIMs and dispensations, etc. are updated for changes in Country Regulation and impacts on business.
- Maintain awareness of operational risk within assigned portfolio and minimise the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.
- Maintain and observe all HSBC control standards and implement, cascade and observe the Group Compliance Policy, including the timely implementation of recommendations made by internal/external auditors and external regulators for assigned area
- Ensure that all employees are aware of and effectively identify and manage applicable money laundering (ML), terrorist financing (TF), sanctions and reputational risks.
- Complete other responsibilities, as assigned.
- To take the complexity of the regulations on the one hand, and the diversity of business and geographies within the Region, and achieve a balance between the demands of the regulators, external bodies and governmental initiatives and the Group’s shareholders and customers.
- The incumbent is required to assist the Head of Sanctions Canada with ensuring the consistent application of the highest Risk management standards notwithstanding the complexities of products and business operations across regions. Risk is forward looking. The incumbent would implement change programmes regionally to ensure that the FCC Sanctions remains in line with regulatory requirements across the Region. A balance must be maintained between the local, regional and global priorities. The incumbent would need to balance between sometimes conflicting needs and priorities of different teams within Risk departments and across the Region under the leadership of the Canadian Head of Sanctions.
- The jobholder is required to work independently, dealing with issues for which there is not always a clear cut solution while still being able to provide judgement and clear direction. Where items of major consequence are involved, reference is made to the Head of Sanctions and the Assistant Chief AML Officer. The nature of the role requires close working contact with senior managers and colleagues in FCC and the business.
Management of Risk
- Ensure compliance of both general and anti-money laundering and anti-terrorist financing (AML/ATF) compliance controls as well as operational risk controls in accordance with HSBC or regulatory standards and policies; and optimize relations with regulators by addressing any issues.
- The jobholder is responsible for ensuring that the FCC Sanctions standards are in accordance with the Group Standards Manual at local levels and that the Sanctions policy aspects of the Legal & Compliance FIM are effective and relevant.
Observation of Internal Controls
- Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.
- Jobholder is an ‘insider’ for dealing purposes and subject to strict controls and confidentiality.
- Jobholder is required to assist with managing FCC responses to adverse compliance metrics, including unsatisfactory FCC Reviews and Audit reports.
- This will be achieved by adhering to all relevant processes/procedures and by liaising with Financial Crime Compliance department about new business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimising relations with regulators.
- The jobholder will also adhere to and be able to demonstrate adherence to internal controls. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators for assigned area.
Skills and Qualifications:
- Bachelor degree or equivalent experience. LL.B or legal experience an asset.
- Seasoned professional with 5-7 years proven and progressive financial services, compliance or legal experience or equivalent, ideally to include Sanctions experience.
- Knowledge of Sanctions regulations and guidance.
- Specialized knowledge of regulations and sanctions programs- Department of Foreign Affairs, Trade and Development / OSFI. Knowledge of OFAC requirements an asset.
- Ability to review and understand complex regulations
- Knowledge of the HSBC Group structure, its business and personnel, and a deep understanding of HSBC’s corporate culture an asset.