Responsible for leading periodic functional reviews of assigned areas within the Second Line of Defense Compliance teams, U.S., in accordance with a continuous risk based methodology and in support of the Global Assurance operating model. Uses technical expertise and experience to contribute to reviews of assigned areas. Develops a test plan of reviews and work plan for assigned areas of Compliance to determine whether assigned areas of Compliance are operating effectively and as expected.
Manages and executes all preparation and reporting associated with the functional reviews. Identifies items requiring further investigation through review of key metrics and targeted interviews and questions.
Serves as the department technical expert for assigned areas of Compliance, including regulatory aspects. Interacts with senior management within Compliance and business lines associated with assigned areas.
Impact on the Business
Updates Universe (assessable units) at least annually.
Leads reviews of assigned Compliance functions in accordance with the planned review schedule. Contributes to determination of review schedule based upon continuous risk based model, risks identified and experience.
Oversees creation and issuance of reports of each functional review; communicates and agrees to findings and corrective action with stakeholders.
Partners with management to drive change within the Compliance Function, as appropriate, based on the functional reviews.
Effectively engages with senior stakeholders to ensure timely implementation of management action plans. Reports overdue remediation of management action plans.
Determines key reporting and information for management related to areas of focus based on the functional reviews.
Contributes to the development of procedures and controls for the department which are complete, effective and well documented.
Ensures all work is performed, controlled and documented in accordance with Functional Instructions Manual (“FIM”), Global Standards Manual (“GSM”) and HSBC Policy requirements contributing to satisfactory internal audit review findings.
Participates in various governance committees as a delegate.
Customers / Stakeholders
Fosters a positive culture of compliance by working proactively with the business, Compliance Officers (“COs”), Business Risk & Control Management (“BRCM”), internal controls functions, and other Compliance professionals to ensure that best practices and systems are in place to facilitate business growth and the overall success of HSBC in accordance with applicable laws, rules, regulations and internal policy.
Provides support to ensure U.S. Regional Assurance is aligned with global objectives.
Responsible for maintaining strong relationships with key stakeholders in RC, U.S. and FCC, U.S.
Collaborates and fosters good relations with Risk and Internal Audit at the most senior levels within the U.S.
Documents Regional Assurance Change Management Plans and reviews results of ongoing change management activities.
Leadership & Teamwork
Demonstrates leadership skills and contributes to an effective team through communication and training for team members, addressing and resolving issues and a strong work ethic.
Provides project management support, as requested, on compliance-related projects and initiatives to ensure they progress toward a common goal in alignment with agreed timelines.
Lead and develop an effective team through communication, performance management, development plans and reward/recognition practices.
Promote an environment that supports diversity and reflects the HSBC brand.
Operational Effectiveness & Control
Assists senior management in identifying, maintaining and continuing to improve an environment and culture of compliance.
Maintains awareness of major regulatory changes affecting assigned coverage areas; ensures appropriate communication and development of appropriate policy/procedure changes to remain compliant.
Maintains a current knowledge of industry compliance initiatives pertaining to areas of responsibility and best practices.
Acts with high levels of integrity, conduct, and performance against ethical standards.
Implements the Group compliance policy locally by managing compliance risk in liaison with the Global Head of Compliance, Global Compliance Officer, Area Compliance Officer or Local Compliance Officer, ensuring adequate compliance resources and training, fostering a compliance culture and optimizing relations with regulators.
Discharges Compliance Officer accountabilities by pro-actively assisting management in identifying and containing compliance risk, monitoring, reporting and certification, fostering a compliance culture and optimizing relations with regulators.
To implement the Group compliance policy locally by containing compliance risk in liaison with the Head of Group Compliance, Global Business Compliance Officer, Area Compliance Officer or Local Compliance Officer, ensuring adequate compliance resources and training, fostering a compliance culture and optimizing relations with regulators.
Complete other responsibilities, as assigned.
Major Challenges
Establishing department as “value-add” to senior compliance executives who currently face a number of ongoing internal and regulatory reviews; ensures findings, reports and recommendations are implemented timely.
Implementing assurance program in an environment which is undergoing a great deal of change and regulatory scrutiny.
Major contributor to the development of a new department within the U.S. Compliance team.
Role Context
This is a critical role within the Compliance department. The job holder must have the technical expertise and experience to be able to contribute to the design of a program and to execute the program to determine if the assigned areas within the U.S. are operating effectively.
Each incumbent is responsible for reviewing assigned areas within U.S. Compliance (1) Financial Crime Compliance including: Bank Secrecy Act/Anti-Money Laundering, Sanctions and Anti-Bribery and Anti-Corruption compliance programs (2) Regulatory Compliance – Banking including: compliance programs for commercial, retail and private banking activities and (3) Regulatory Compliance – Securities including: compliance programs for broker dealer and asset management activities.
To fulfill on a timely basis a schedule of reviews of all U.S. Compliance functions, in accordance with the Compliance FIM, Sections B2.1.3, the job holder will be expected to instruct and direct other members of the team and make decisions based on their knowledge and experience. When unsure, guidance should be sought from job holder’s direct manager or Group Assurance. The job holder is expected to act proactively and develop ideas for enhancements to the department’s activities.
Management of Risk
Ensure employees apply compliance, operational risk controls in accordance with HSBC or regulatory standards and policies; and optimize relations with regulators by addressing any issues.
Ensures compliance and operational risk controls are in accordance with HSBC and regulatory requirements, expectations, standards and policies; and optimize relations with regulators by addressing any issues. Optimizes relations with regulators by addressing any issues.
Adheres to the Firm’s Statement of Business Principles and Code of Ethics.
Is aware of Business Regulatory Risk associated with the business. Monitors in accordance with the Principal Accountabilities set out above.
Observation of Internal Controls
Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.
Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators and reported through the Compliance Risk Committee. Helps to ensure alignment with regulatory requirements, the Compliance FIM, HNAH’s Enterprise Compliance Policy and Program, the CRMP Manual, HNAH’s BSA/AML Policy, other Group policies and all related policies and procedures.
Provides support to ensure Compliance Assurance is aligned to regulatory requirements, the CRMP Manual and other Group policies.
Qualifications
Minimum Bachelor’s degree in related business field, or comparable experience required
Minimum of fifteen years proven and progressive financial services auditing/Compliance testing experience. CIA, CPA, CRCM, CFSA and/or CAMS certification a plus.
Proven technical expertise related to assigned areas.
Financial Crime Compliance incumbent should have minimum of ten years of experience working with AML and Sanctions Compliance programs. Anti-Bribery and Anti-Corruption compliance experience is a plus.
Regulatory Compliance Banking incumbent should have a minimum of ten years of experience working with varied aspects of Banking compliance programs. Incumbent should have experience with Regulatory Compliance programs supporting commercial, retail and private banking activities.
Regulatory Compliance - Securities incumbent should have a minimum of ten years of experience working with compliance programs supporting a broker/dealer and have knowledge of products (equities, fixed income, derivatives), how products trade and how the capital markets process works. FINRA Series 7, 9, 10, 24, 63 and/or 79 licensing is a plus. Investment Advisor compliance program experience is also a plus.
Strong knowledge of banking regulations, businesses, products, operations, and systems. Strong understanding of significant regulatory compliance requirements applicable to the business.
Excellent communication skills both oral and written; strong analytical skills and ability to articulate results of complex analyses/report findings; successful track record of agreeing difficult findings with stakeholders.
Experience and successful contribution to the formation of a new department, group or project, a plus.
Proven ability to manage conflicting priorities effectively and proven ability to meet challenging deadlines
Proven leadership skills and ability to accomplish high-level objectives in the context of annual business and compliance plans.
Excellent organizational, project management and planning skills.
Demonstrated tenacity to follow issues through to resolution.
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