Fcc Governance

As part of our business, ING Luxembourg is looking for a:
**FCC Governance & Controls Investigator**

***(M/F)**

Financial Crime Compliance (FCC) Governance & Controls Luxembourg is the second line of defence function supporting ING Luxembourg, its underlying entities and the Anti-Money Laundering (AML) Compliance Manager in managing the FCC risks.

The Governance and Controls function includes oversight of 1st line of defence AML related processes & sourced activities, the monitoring of customers’ activities (aka Transaction Monitoring) as well as the investigation of atypical & complex cases regardless of the source of identification (Adverse Media Screening, Transaction Monitoring, Name Screening,) and the handling of special requests (Police, Prosecutor, FSMA, FIU,...).

The mission of Governance and Control team aims to identify and report on emerging threats and risks stemming from known and evolving forms of Financial Economic Crime (FEC), such as money-laundering, terrorist financing, corruption, and transnational and organised crime.

The team is working together based on knowledge and expertise, as well as the skill set needed to best perform the job.

You report hierarchically to the Head of the FCC Governance & Controls, who reports to the Head of Financial Crime Compliance, being the Anti-Money Laundering Compliance Manager of ING Luxembourg.

**Description of the function**:
The role of the FCC Governance & Controls Investigator is critical for the Bank’s defence against money laundering, terrorist financing and fraud. As a senior expert with a strong focus on investigation, you take part in the execution and further development of the anti-money laundering strategy of the Bank by reviewing client’s profile and transactions, reporting unusual transactions, analysing trends and providing input on emerging risk or risk typologies to strengthen the existing risk control framework. Next to this, you will ensure adequate reporting towards internal & external clients and take the lead to convert the outcome of your investigations, trends analysis and quality controls into pro-actively sharing of lessons learned and defining & implementing the training needs for 1st and 2nd line of defence colleagues on emerging risks, typologies, best practices, do’s and don’ts.

You will be responsible for the following (non-exhaustive) overview of activities:

- Review Financial Crime Compliance alerts escalated by 1st line of defence or other compliance teams, which includes Transactional Monitoring alerts or any other Unusual Activity Reports (atypical cases) or requests for analysis received, in line with prescribed procedures and determine whether transactions occurring are valid Anti-Money Laundering (ML), Terrorist Financing (TF) or Sanctions Evasion risks by:

- Evaluating transactions and customer relationships for ML/TF/Sanctions activities, identifying red flag issues & potential suspicious activities and performing in depth-investigation within the FCC framework when needed;
- Handle periodic and immediate Name Screening cases (TER);
- Effectively communicating with business lines and/or Safe Business Officers to obtain additional information and documentation as needed;
- Preparing suspicious transaction report & suspicious activity report (SAR) filing;
- Maintaining accurate and concise records of all investigations undertaken including details on the rationale for any decisions made;
- Ensure adequate follow up by 1st line of defence of alerts / cases investigated by FCC Governance & Controls function;
- Ensure the 4 eyes on cases handled & SARs prepared by less experienced colleagues;
- Monitor the queues for alerts for ensuring adequate management of outstanding alerts and prioritization rules;
- Perform trends analysis, investigation of complex / special cases (FSMA/NBB requests; request for information from FIU/Police/Prosecutor );
- Provide guidance, insight and investigate alerts escalated to 2nd LOD in the framework of lookback exercise;
- Ensure the creation and maintenance of the procedures and WPI of the team and sourced FCC activities; challenge the 1st line of defence procedures and WPI’s (incl. training & instructions) on AML-related processes;
- Provide advice and support to the Bank’s business units on a case by case basis, when needed and support these units on the identification of areas of risk as a result of transaction monitoring trends and other in-depth investigations and trend analyses;
- Ensure continuous quality controls on the full E2E AML-processes, including process steps performed by 1st line of defence and sourced activities as well as on own activities;
- In close collaboration with colleagues of other compliance teams, promote/enhance the knowledge and awareness with regards to FCC within the organisation;
- Represent the FCC Governance & Controls team in projects, workgroups by coordinating, providing input, defending his/ her position, challenging the