Head Financial Crime Compliance

**Head Financial Crime Compliance - Retail**

**Role & work environment**

Financial Crime Compliance Retail Luxembourg (FCC Retail) team within the compliance department is the second line of defence function supporting the Retail and Private Banking segment in Luxembourg for the purpose of managing Financial Crime Compliance (FCC) risks.

The team of retail FCC specialists (advisors) is dedicated to support the retail business in complying with FCC policies and regulations in line with the Compliance Risk Management Charter by performing horizon scans, maintaining the policy framework, supporting & challenging risk assessments, delivering advices, assuring training & awareness, tracking issues and escalating where and when needed. At the same time it looks for global alignment and uniformity in approach in order to contribute to efficient KYC-processes and a flawless client experience. 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 Financial Crime Compliance ING Luxembourg.

**Key responsibilities**

As head of the FCC Retail team you manage, motivate and coach a team of experts, which is the key and expert channel for advice, training, translating (external) developments to the retail banking environment as well as communicating and sharing of best practices related to the FCC retail domain.

As a content matter expert and decision maker you are also responsible for taking final decisions on specific files as well proposed solutions being implemented.

Together with the head of FCC Retail and the head of FCC Governance and control, you are, jointly responsible in managing and monitoring risks in close cooperation with the Anti-Money Laundering Compliance Manager on Anti-Money Laundering (AML), Economic and Financial Sanctions including Controls and Proliferation Financing which translates to the following (non-exhaustive) overview of activities, which you will execute:

- Lead a team of FCC Retail advisors:

- o Steering of the compliance activities in the FCC retail banking area with the help of a team of compliance advisors;
- o Ensure the continuous development of compliance knowledge and expertise within the FCC Retail team and contribute to the same within the wider ING compliance community;
- o Create a productive and constructive collaboration and exchanges within the team as well as with other compliance teams (e.g. FCC Retail team, FCC Governance & Control team, Quality Assurance team);
- o Support the team members in the execution of their activities; take as a content matter expert final decision when needed;
- o Cover all HR related activities, including performance management;
- o Contribute to the dynamic planning.
- Set together with the team solid, future proof compliance standards and advice & steer on these standards:

- o Point of escalation and coordination for Retail Luxembourg including financial institutions, specifically:

- Analysis, challenging and advice on customer due diligence escalations triggered by:

- new client Onboarding;
- client reviews (periodic, event driven) including transaction analysis;
- Offboarding;
- Waivers.
- Analysis, decisioning and follow through on FCC alert escalations triggered by Negative News Screening.
- o Support the business, FCC Luxembourg and FCC Belgium/ Corporate FCC function in maintaining the retail FCC control framework by translating regulations and requirements to practical implementable policies, guidelines, instructions or solutions;
- o Advising on risk appetite setting and translation thereof in compliance related processes;
- o Pro-actively oversee and advice (partner) with our Luxembourg and global retail businesses on the embedding of the FCC controls within the retail domain by analysing and formulating advices on the compliance risks of products, processes or projects or delivering support and challenge when needed any risk assessment or mitigation (e.g. participating SIRA). Work from the basis of what’s possible within the confines of law and regulations and at the same time enabling the business in achieving sustainable growth. Proceed to instructions or escalation if advices are not considered.
- o Assure in close cooperation with the retail business that all identified FCC risks are correctly registered in I-Risk and follow-up the correct closure of the mitigating actions. Pro-actively inform compliance management on the evolution of the FCC compliance risk management in your domain;
- o In closed collaboration with colleagues of other compliance teams, promote/enhance the knowledge and awareness with regards to FCC within the organisation by o.a. liaising with 1st line of defence (senior) management and contribute to the drafting and/or implementation of the annual compliance training plan.
- Pro-active Report and steer improvements:

- o Identify key areas for improvement and provide support and guidance to