Senior Financial Crime Compliance Officer

About the Company

- The Bank of Communications (Luxembourg) S.
A. (“Bocom Lux”) is a wholly-owned subsidiary of Bankof Communications Co., Ltd (“Bocom”). As the European hub of Bocom, Bocom Lux has branches in Paris and Rome. Founded in 1908, Bocom is one of the banks with the longest history and one of the first note-issuing banks in China. Listed on the Hong Kong / Shanghai Stock Exchange, it has 24 overseas branches (subsidiaries) and representative offices around the world, provides comprehensive financial services. It is one of the Global Systemically Important Banks (G-SIBs) (FSB, Financial Stability Board), ranked 9th among “Top 1000 World Banks” in terms of Tier-1 Capital (“The Banker”), also on the “Fortune Global 500” list.

About the Role
Reporting to the Chief Compliance Officer, who holds the statutory RC/MLRO responsibility, you will act as the Luxembourg subject-matter expert for anti-money laundering, counter-terrorist financing, counter-proliferation financing and financial sanctions. You will combine hands-on second-line oversight crime risk framework, covering the Luxembourg entity and supporting its European branches. This is a senior specialist position with substantial autonomy and direct exposure to internal audit, external auditors and possibly authorized management. Responsibilities
- Own and maintain the local AML/CFT, counter proliferation financing and sanctions framework, ensuring alignment with Luxembourg and EU requirements, CSSF expectations and applicable group standards.
- Provide authoritative second-line advice and challenge to the first line of defence on customer acceptance, ongoing monitoring including unusual and suspicious transaction monitoring and name screening duties
- Lead the preparation and periodic update of the business-wide AML/CFT and proliferation-financing risk assessments, sanctions exposure assessments, risk appetite metrics and related methodologies.
- Perform financial crime risk assessments for new products, services, delivery channels or any material changes, and define proportionate mitigating controls.
- Design, maintain and test policies, procedures, control plans and management information; identify weaknesses, propose remediation and follow-up through closure.
- Oversee the effectiveness and calibration of KYC, screening and transaction-monitoring systems, including scenarios, thresholds, data quality, alert governance, user acceptance testing and change implementation.
- Monitor Luxembourg, EU and international regulatory developments, conduct gap analyses and translate new requirements into practical implementation plans and controls.
- Assist in the preparation of reporting to the authorized management, board of directors, internal and external auditors, group stakeholders and supervisory authorities.
- Contribute to regulatory audits and remediation programmes where any
- Provide awareness raising session to the first line of defence and contribute to developing a strong financial crime compliance culture.

Your profile

- At least 5 years relevant experience in AML/CFT, counter-proliferation financing and/or sanctions compliance, including substantial experience within a bank or comparable regulated financial institution.
- Fluent in written and spoken English and Chinese.
- Strong experience with corporate and institutional clients, complex and cross-border structures, transaction monitoring, sanctions screening and enhanced due diligence. Exposure to trade finance and payment services may represent a significant advantage.
- Familiarity with Luxembourg and EU banking regulatory environment and related local benchmarks
- Demonstrated experience leading or significantly contributing financial crime systems implementation, migration or optimisation projects. Disclaimer: The preceding description is not designed to be a complete list of all duties and responsibilities required of the position Senior Compliance Officer. In accordance with the provisions of the Luxembourg Law of 23 July 2016 amending the Law of 29 March 2013, candidates may be required to provide an extract from their criminal record. This document, issued by the authorities, must have been issued within the last 3 months. This document is requested to carry out a background check on candidates, taking into account the field in which the BoCom operates and, more specifically, the tasks described in this

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