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Group Head of Financial Crime

Information About This Job

Job Title: Group Head of Financial Crime
Location: London
Salary: Competitive Salary
Contact Name: Ben Kinley
Contact Email:
Job Published: over 1 year ago

Job Description

We are recruiting for Group Head of Financial Crime on behalf of our client, a London based professional services firm.


About The Company

The firm operates a 'three lines of defence' governance model abd the Group Head of Financial Crime is a Group-wide role that reports to the Group Head of Risk who owns the second line of defence as defined in the table below:


Line 1

Comprising the Group Executive Committee (GEC), trading and subsidiary boards and all operational controls, including quality assurance processes. Certain of these functions may be provided through shared services facilities such as the firm's Management Services Limited. Each business is responsible for the identification and implementation of the controls, policies and procedures to ensure risks are properly controlled and mitigated.


Line 2

Comprising Group Risk & Compliance (GRC), which includes specialist areas / teams such as Data Protection, Financial Crime Prevention, Compliance Monitoring and Enterprise Risk Management.  GRC sets Group level policy (in the areas falling within its remit), provides oversight and challenge, advice on more complex matters and monitoring of policy implementation at business level.


Line 3

Comprising the Group Internal Audit (GIA) department. GIA's primary role is to help protect the assets, reputation and sustainability of the company. It does this by independently assessing whether all significant risks are identified and appropriately reported to the Board (via the Group Audit & Risk Committee) and Executive Management; assessing whether they are properly controlled; and by challenging Executive Management to improve the effectiveness of governance, risk management and internal controls.


About The Role

  • Define/maintain an appropriate, integrated Financial Crime framework across the Group taking into account the size, nature, complexity and risk profile of the organisation;

  • Assess and monitor the Financial Crime profile, and ensure that an appropriate control environment is defined across the Group to mitigate risk to a level aligned with the Group's risk appetite. This will include leading Financial Crime projects to strengthen the Group's Financial Crime processes and tools;

  • Deliver Financial Crime risk Management Information to aid the Group's understanding of its risk profile, financial crime risk events and the progress of key initiatives and control enhancements;

  • Provide technical Financial Crime leadership and advice to Risk & Compliance and the businesses across the firm;

  • Play a leadership role in managing Financial Crime investigations, working with Group Legal and other key functions;

  • Act as the Money Laundering Reporting Officer ("MLRO") and advise the Group on it external reporting requirements;

  • Have management responsibility for the teams that make up Group Financial Crime - Anti -Money Laundering / Sanctions, Investigations and Anti-Bribery & Corruption / Third Party Payments;

  • Build and maintain appropriate Financial Crime awareness and capability within 1LOD Risk & Compliance around managing Financial Crime risk;

  • Ensure the Group is aware of, and meets its legal and regulatory obligations in respect of Financial Crime related regulation and legislation, and liaise with regulators and governmental organisations e.g. Export Control Organisation, Treasury, National Crime Agency and the international equivalents as required;

  • Provide oversight and challenge on the 1LODs application of Financial Crime policies and controls;

  • Undertake any ad hoc reviews that may be required e.g. mergers and acquisitions due diligence;

  • Develop a strong risk community across the company who are well trained in the Risk Framework, able to facilitate the risk vs reward debate locally and are culturally aligned to the stated risk culture principles set out in the Group's Risk Management Policy;

  • Ensure suitable Financial Crime governance is in place, and working effectively;

  • Oversee the shared service for client on boarding for UK businesses, and be an expert reference point or point of escalation for sanctions processing hubs; and

  • Support the due diligence process in respect of potential M&A targets.


Key Responsibilities

The Group Head of Financial Crime will deliver their responsibilities across the Group working with the Group Head of Enterprise Risk Management, the Group Head of Compliance, the Group Head of Risk, together with other areas of GRC as required.

The Group Head of Financial Crime manages a team of Financial Crime specialists who form part of the second line of defence. The specialist areas include Anti-Money Laundering / Sanctions, Third Party Payments / Anti-bribery and Corruption and Fraud & Investigations. 

The Group Head of Financial Crime will need to operate internationally on Financial Crime matters and have Group responsibility for Financial Crime oversight. They will work with the 1LOD Regional Heads of Risk & Compliance, who have primary responsibility for co-ordinating risk and compliance activity for those businesses. The Regional Heads of Risk & Compliance have a joint reporting line into the Group Head of Risk and the local CEO.

From a UK perspective, the Group Head of Risk and the Group Head of Compliance have the primary responsibility for the relationship with the FCA. The Group Head of Compliance co-ordinates the FCA activity on a day to day basis, working with each business to ensure the organisation has a professional and transparent relationship with the UK regulator. The Group Head of Financial Crime will engage with the FCA on Financial Crime related matters when asked to by the Group Head of Risk or Group Head of Compliance. The international regulatory relationship management is the responsibility of the 1LOD Regional Heads of Risk & Compliance working with the local CEOs, who will similarly request the Group Head of Financial Crime's involvement when appropriate.

The role incorporates the following core responsibilities but will be asked to participate in other reviews, investigations and projects as required by the Group Head of Risk:

  • Develop and maintain a Financial Crime Framework and policies and programmes for Anti-Money Laundering / Sanctions, Third Party Payments / Anti-Bribery & Corruption / Fraud;

  • Undertake financial crime risk related assessments;

  • Develop and execute (including creating, amending, implementing and / or maintaining procedures, processes and forms) the risk based approach for Financial Crime based on the risk assessment and risk appetite;

  • Provide direction on planning, implementing and overseeing Anti Money Laundering / Sanctions, Third Party Payments / Anti-Bribery & Corruption / Fraud strategies and other related financial crime matters;

  • Ensure the Group has appropriate tools and systems in place to manage its key Financial Crime risks, and manage the relationship with providers;

  • Maintain and enhance an effective Third Party due diligence and payment process for the Group;

  • Chair the Group Third Party Payments Forum (TPP Forum), and ensure that the TPP Sub-committees are in place where required and working effectively;

  • Drive the enhancement of the Group's Sanctions screening capabilities;

  • Evaluate reports of suspicious / unusual transactions and filing suspicious activity reports as necessary;

  • Define and supervise the periodic review and challenge of operations' key Financial Crime controls;

  • Lead the investigation of material financial crime risk events;

  • Work with 1LOD regional Head of Risk and Compliance on international investigations;

  • Act as the liaison with law enforcement agencies for financial crime matters and investigations;

  • Evaluate new products and services, clients and geographies the determine the level of financial crime risk and policies and procedures for the business to follow in order to mitigate those risks;

  • Work with other departments, where appropriate, to develop training materials and co-ordinating / delivering financial crime training; 

  • Remaining up to date with changes in regulation, legislation and market practice;

  • Define and produce effective Financial Crime Management Information;

  • Provide oversight over the Shared Service for client on boarding for UK businesses and ensure the service is delivered in a timely way, and performance is in line with expectations;

  • Perform ad-hoc projects as required including undertaking Financial Crime due diligence on potential M&A targets;

  • Ensure the entire Financial Crime team/community remains 'competent' against Group standards;

  • Assist the Group Head of Risk with reports to the Audit and Risk Committees;

  • Lead, coach, manage and maintain an experienced, high performance Financial Crime team;

  • Agree the expectations of the team with the Group Head of Risk and ensure that these are clearly communicated with the individual team members, assessed as part of the objective setting and reviewed during the annual appraisal cycle.


Key Competencies

  • Leadership and teamwork:

    • Provide commercial and pragmatic leadership to the Financial Crime function ensuring the function achieves its goals, responsibilities and objectives;

    • Provide leadership and management to the Financial Crime team by setting standards, objectives and goals for the function and by providing feedback to the whole team and to individuals;

    • Provide direct, clear professional advice and challenge to the senior management of the business in areas of financial crime risk, compliance and controls;

    • Be a strong, collaborative, insightful member of the GRC management team;

    • Be confident, professional, clear and direct about the subject;

    • Be able to hold ground on important, material issues in the face of challenge from senior colleagues;

    • Be a self-starter and use initiative as a senior member of the risk and compliance community;

  • Communication:

    • All written and verbal communication needs to be clear, concise and professional;

    • Effective report writing skills are a pre-requisite of the role;

    • Presentational skills are also important;

    • Be clear about who the key stakeholders of the role are at Group and business level. Devise a strategy to communicate effectively and regularly with each of them;

    • Build appropriate relationships with internal and external parties in order to aid the efficient and productive working relationship between GRC.


Skills & Experience

Ideal candidates will posess :

  • A strong technically proficient and pragmatic leader and self-starter, who actively manages the teams performance and development;

  • Proven track record of strong influencing skills and implementing through communities without the need for direct reporting lines;

  • Must be strong, confident persuasive communicator (oral and written) and capable of robust dialogue, and being clear and resolute on the 'non negotiables';

  • Proven experience, gravitas and capability to work with senior management and deliver credible advice/direction;

  • Resilient, and comfortable managing competing priorities

  • Strong understanding and working knowledge of current industry Financial Crime practices and implementing frameworks;

  • In depth knowledge of the UK regulatory and legal environment in relation to Financial Crime within which the firm operates, particularly UK;

  • Significant breadth and depth of knowledge and experience across Financial Crime - Anti-Money Laundering / Sanctions, Third Party Payments / Anti-Bribery & Corruption and Fraud and investigations practices and technique;

  • Experience of regional / global roles, working with overseas operations, and demonstrable understanding and experience of the 'cultural dimension';

  • Previous experience of running a Financial Crime team in another large financial services company (broker, bank, insurer), insurance sector experience preferable.  Likely to have >7 years' experience;

  • Strong track record of leading / managing complex investigations and Third Party Payments / Anti-Bribery & Corruption risk management processes preferred.


Additional Information

Internal Stakeholders

  • Group Finance Director

  • Group General Counsel

  • Group Head of Risk

  • COO and CEO of all business and at a Group level

  • Regional Heads of Risk & Compliance

  • Group Risk & Compliance teams

  • 1LOD Risk & Compliance leadership

  • Audit & Risk Committee of various Businesses  


External Stake Holders:

  • Regulators: UK (Financial Conduct Authority) and overseas regulators and agencies e.g. Monetary Authority of Singapore, Department Of Justice 

  • Other: National Crime Agency, Economic Control Organisation, HM Treasury, City of London Policy, Trade Bodies/Associations, Financial Crime Peers, external legal counsel, investigative and forensics firms