Senior Compliance Officer

Senior Compliance Officer - Financial Crime Compliance - Corporate Sector

Role & work environment

The Financial Crime Compliance Wholesale Luxembourg (FCC Wholesale Banking) team within the compliance department is the second line of defense function supporting the wholesale segment in Luxembourg for the purpose of managing Financial Crime Compliance (FCC) risks.

The team of Wholesale Banking FCC specialists (advisors) is dedicated to support the wholesale 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[1]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 the FCC Wholesale Banking Team, who reports to the Head of Financial Crime Compliance of ING Luxembourg.

Key responsibilities

The position is a key channel for advice, training, translating (external) developments to the wholesale banking environment as well as communicating and sharing of best practices.

As an expert in the FCC domain your main focus lies on Anti-Money Laundering (AML), Economic and Financial Sanctions including Export Controls and Proliferation Financing which translates to the following (non-exhaustive) overview of activities, which you will execute autonomously or in cooperation with senior team members:

- Point of escalation and coordination for Wholesale Luxembourg, 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:

- Pre transactions screening;
- Name screening (PEP);
- Negative News Screening.
- Advice on flagged corporate lending and trade finance transactions.
- Support analyses, advices and investigations related to correspondent banking activities;
- Support the business, FCC Luxembourg and Belgian/ Corporate FCC function in maintaining the wholesale and correspondent banking FCC control framework by translating regulations and requirements to practical implementable policies, guidelines, instructions or solutions;
- Advising on risk appetite setting and translation thereof in compliance related processes;
- Pro-actively oversee and advice (partner) with our Luxembourgish and global wholesale businesses on the embedding of the FCC controls within the wholesale 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;
- Assure in close cooperation with the wholesale 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;
- In close collaboration with colleagues of other compliance teams, promote/enhance the knowledge and awareness with regards to FCC within the organisation and contribute to the drafting and/or implementation of the annual compliance training plan;
- Represent the FCC Wholesale Banking team in projects, workgroups by coordinating, providing input, defending his/ her position, challenging the discussions and communicating the output to the members of the team;
- Identify key areas for improvement and provide support and guidance to implement good practice; Drive the implementation of automated process, robotics or data analytics techniques in order to maintain the efficiency of the FCC wholesale compliance related processes and tools;
- Support the head of FCC Wholesale Banking in providing clear and convincing compliance risk management reporting in all its forms;
- Contribute to the Group FCC enhancement program, as applicable to Luxembourg;.
- Oversee and advice (partner) with our Luxembourg and global WB businesses on the embedding of the FCC controls within the WB domain;
- Align the activities and seek for uniformity in approach of the WB MLRO/FCC community with the global functions;
- Be a support and coach for his/ her junior colleagues and helps them in their challenge an decision making.

Key Competences
- A colleague with a talent for taking i