Senior Compliance Officer - Financial Crime Compliance - Corporate

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:

• Maintaining expertise and in depth subject knowledge and understanding of good practice and procedures in the FCC domain (continuous development) in Wholesale banking;

• 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 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 love to challenge the status quo and are eager to propose creative solutions to problems.
• As a FCC WB Associate Compliance Officer you will also need:
• A master degree in Law, Economics or equivalent in experience;
• Minimum 4 years’ work experience, experience in the wholesale or correspondent banking world, ideally with a compliance, legal, non-financial risk and/or project management background is a plus; Good knowledge on the industry trends and ever changing FCC compliance regulations & procedures; Strong in written and spoken English;
• French and/or Dutch are beneficial;
• Good analytical skills, interest for data (analysis) and the way to process them, as well as a keen eye for detail;
• Good knowledge of Excel, Powerpoint, knowledge of other software application is a plus;
• Able to use different communication styles fitting with the need of the (internal) customer, both verbally and written;
• Being able to quickly integrate new concepts, procedures, modifications in the organisation or methodologies;
• Good skill set in the areas of personal effectiveness (i.e. autonomy, team spirit, courage and self-confidence, problem solving & result oriented by delivering as promised, “hands-on”, good written and oral communication, capable to work in changing circumstances, customer focus and investigative & learning ability).

Your working environment :

With over 1000 employees in the Grand Duchy and thanks to the combination of our local presence and the strength of a robust multinational like ING, we offer our retail and professional customers a wide range of solutions through the channel of their choice. ING is a global bank with a strong European base. 53,000 employees serve around 38.4 million customers, businesses and financial institutions in more than 40 countries. Operating in the Grand Duchy of Luxembourg since 1960 as a universal and accessible bank, our products include savings, payments, investments, loans and mortgages for retail and private banking customers, whom we serve severely online and through our branch network. For our wholesale banking customers, we provide loans, sustainable finance, payment and cash management services and fund services