Anti-Bribery & Corruption Officer

Job Description

Description of the Business Line or DepartmentThe key objective of the Financial Crime Team is to prevent SG Kleinwort Hambros (KH) breaching any law or regulation relating to financial crime by providing guidance to the SG Kleinwort Hambros Group on anti-money laundering, countering terrorism financing,the criminal facilitation of tax evasion, sanctions and embargoes and anti-bribery & corruption (collectively "financial crime").Summary of the key purposes of the role

• To monitor the effectiveness of the KH ABC Compliance Program on a group wide basis, and ensure that ABC related policies, procedures, systems and controls are being complied with, working effectively and are properly embedded across all group entities.
• To provide ABC related management information (MI) to senior management, commercial directors and key support functions to evidence the effectiveness of the KH ABC compliance program on a group wide basis and to inform decision making at all levels of theorganisation.
• Act as the main point of contact for all anti-bribery & corruption related matters with Head Office, regulators and government agencies.
• Assist the Group Head of Financial Crime and the Group Head of Tax in building and developing its tax evasion facilitation offence (TEFO) compliance program on a group wide basis.

Summary of responsibilities

• Updating ABC related policies, procedures and guidance notes on a routine basis to ensure compliance with the SG Code and all applicable laws and regulations relating to ABC, particularly the UK Bribery Act 2010, the US Foreign Corrupt Practices Act 1977,the French SAPIN II Law 2016 and local legal / regulatory requirements in the Channel Islands and Gibraltar.
• Providing day to day compliance advice to the KH businesses on all ABC related enquiries and escalations.
• Overseeing the delivery of the KH group wide ABC risk assessment / risk mapping exercise on an annual basis and socialising the results with the KH Executive Committee, Boards and Local Management Committees.
• Advising the business on client and third-party due diligence requirements and acting as an approval authority at the Relationship Risk Assessment Committee (RRAC) for higher risk relationships from an ABC perspective.
• Conducting routine monitoring and assurance work alongside the KH Compliance Monitoring Team to ensure that ABC compliance requirements are being adhered to on a group wide basis, and that any identified compliance breaches / control deficiencies are identifiedand handled in an appropriate manner.
• Completing operational risk and control assessments (such as GPS, RAMOS and the RCSA exercise) as they relate to ABC compliance topics.
• Identifying ABC related training needs and overseeing the delivery of online and face to face ABC compliance training for KH staff.
• Liaising with Head Office (CPLE PRIV and CPLE REO) to ensure that group ABC projects and initiatives are implemented at KH within group approved deadlines.
• Developing and strengthening relationships with business heads, relationship managers, support function managers and KH staff to promote best practice, a culture of compliance and a good understanding of anti-bribery & corruption requirements across alllevels of the organisation;
• Assisting the Group Head of Financial Crime with strategic initiatives and compliance projects beyond ABC when requested; particularly with respect to the tax evasion facilitation offence and broader efficiency initiatives.

Competencies

• Individual contributor competencies as defined in the SG Leadership Model
• Experience in Private Banking/Wealth Management
• Team Spirit & Collaboration
• Knowledge of regulatory and legal requirements with respect to anti-bribery & corruption
• Knowledge & experience of providing guidance on anti-bribery & corruption to staff / management
• Communication - written & verbal to all levels of the organisation (including Head Office) and to external third parties including regulators.
• Decision Making - consider & recommend escalation to Head Office, regulators and relevant government agencies when necessary
• Influencing - persuade and influence management and staff across KH
• Project Management - participate and where necessary lead/manage compliance projects
• Strategic & Commercial Awareness - develop and apply commercial awareness and business acumen in all day to day and longer-term tasks.