Senior Compliance Officer

FCC Retail Senior Compliance Officer Tax

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 segment in Luxembourg for the purpose of managing Financial Crime Compliance (FCC) risks.

The team of Retail Banking 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.

You report hierarchically to the Head of the FCC Retail Team, who reports to the Head of Financial Crime Compliance of ING Luxembourg.

Key responsibilities

The position is a key and expert channel for advice, training, translating (external) developments to the retail Banking environment as well as communicating and sharing of best practices. As an expert in the FCC domain and a point of reference for your colleagues, your main focus lies on Compliance Tax risks: FATCA-CRS, Qualified Intermediary/ US withholding, Client Tax Integrity / Client tax compliance (as foreseen by CSSF Circulars 17/650 and 20/744), DAC 6, as well as Anti Money Laundering and Terrorist Financing.

Being the FCC expert for tax compliance topics above mentioned

Point of escalation and coordination for Retail and Wholesale banking as well as your team members, specifically:

- Analysis, challenging and advice on customer due diligence/tax 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 the business, FCC Luxembourg and Corporate FCC function in maintaining the retail and WB FCC control framework by translating compliance tax 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 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;

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;

In close 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;

Represent the FCC Retail team in programs, internal and external 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 retail compliance related processes and tools;

Support the head of FCC Retail in providing clear and convincing compliance risk management reporting in all its forms, in reviewing internal and assessing external reports and in proposing and/or rolling out changes and improvements;

Align the activities and seek for uniformity in approach of the Retail MLRO/FCC community with the global functions;

Be a support and coach for his/ her colleagues and helps them in their challenge a decision making;

Represent ING towards senior management and third parties (e.g. regulator, CRF).

Key Competences

A colleague with a talent for taking it on and making it happen, enthusiasm for helping others to be successful and a knack for always being a step ahead. In other words, you strive to bring fresh ideas to life and embrace challenges in a fast changing and complex environment. You are a naturally collaborative person who listens and invests in others to achieve common goals. You