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Position Description/Overview:

Recommend Corporate Banking Department (CBD) policies and procedures to enable CBD’s compliance with Know Your Customer (KYC) requirements. Provide guidance and training to CBD business team and Relation Managers (“RM”). Assist RMs to conduct KYC onboarding due diligences and KYC reviews. Monitor and assess CBD’s KYC end-to-end process and quality. Managing compliance risks associated with CBD business activities and take proactive responsibility and accountability in identifying, assessing, monitoring, controlling, and reporting the risks as the 1st Line of Defense.

Responsibilities:

1. Policies, Procedures, Controls and Training：
• Understand KYC program requirements and regulatory KYC expectations;
• Review and update CBD KYC-related policy and procedures for compliance with corresponding regulatory requirements and applicable Branch-level KYC policies;
• Communicate with Legal and Compliance Department (LCD) on behalf of the business teams of CBD to ensure the CBD’s KYC procedures enable compliance with regulatory requirements and LCD policies and procedures;
• Provide clear guidance to Relationship Managers (RMs) with respect to the KYC policies and procedures;
• Design CBD KYC controls to help ensure compliance with KYC requirements and policies;
• Define KRIs and standards for CBD KYC process execution;
• Develop and/or conduct business-side KYC training to ensure the RMs in CBD are adequately trained and informed about bank’s AML/Countering the Financing of Terrorism (CFT) policies and procedures.

2. KYC Onboarding Due Diligence and Reviews：
• Assist RMs with KYC due diligence collection from the customers;
• Prepare the appropriate KYC records, including the completion of the KYC questionnaires and Customer Risk Rating (CRR), and serving as a back-up to RMs for World-Check screening of the customer name, tracking KYC approval progress and following-up with LCD on any outstanding items;
• Work with RMs to obtain a completed Request for Information (RFI) or equivalent from the customer, with RM serving as the customer’s primary point of contact;
• Follow up with the KYC approval progress and help resolving any issues found during the process by 1st or 2nd LOD KYC reviews;
• Work with RMs to conduct periodic KYC file reviews according to LCD’s CRR-based review schedule, and update customer information and CRR as needed;
• Assist RMs to update customer files and CRR, as needed, when notified by the RM of ad hoc changes to customer information and/or product usage.

3. KYC Process Monitoring and Reporting：
• Continuously assess effectiveness and sustainability of the CBD KYC process end to end, from onboarding/approval to periodic or event-driven review, and drive improvement;
• Identify and assess the risks present in KYC files under review; escalate to CBD leadership and LCD as appropriate.
• Prepare weekly KYC activity tracking reports, as well as monthly and quarterly KYC segments of CBD monthly and quarterly reporting;
• Prepare CBD compliance risk KRI regularly and communicate with LCD or other department as needed;
• Prepare breach report with detailed analysis and management plan, follow up with progresses and make sure breach is remediated within the timeframe.

4. Compliance Risk Management
• Follows Branch-wide compliance risk management policies and procedure and performs risk management activities on behalf of CBD;
• Provide input for CBD compliance risk management policies and procedures;
• Perform compliance risk assessment for CBD;
• Support LCD conducting compliance risk related testing;
• Prepare compliance risk related reporting on a regular basis;
• Other regular and ad hoc compliance risk management activities of CBD;
• Work with LCD and other department and participate compliance risk and KYC related systems design, business requirements, UAT and implementation.

5. Other Assigned Tasks:
• Be familiar and comply with the applicable regulatory and Branch’s policies and procedures etc.;
• Assist CBD teammates with the various KYC and client onboarding projects as requested;
• Participate in Branch-wide KYC and compliance risk projects as requested;
• Other ad-hoc tasks assigned by team leader and department head.

Education and Experience Requirements:

• A Bachelor’s degree in compliance, economics, finance, marketing, accounting or related fields;
• Minimum 5 years of KYC or compliance experience.

• Excellent interpersonal skills and ability to interact and build relationships with internal and external stakeholders;
• Experienced in task planning, delegation, progress monitoring and evaluation;
• Experienced in problem identification and solving;
• Experienced in handling and prioritizing multiple tasks;
• Familiar and experience with MS Office system (especially PPT, Excel, Word, etc.);

Summary

Performance of Analyst specific responsibilities as defined within the global Client Lifecycle. Management procedure of the Corporate Client segment (and/or local addendums) under the guidance and supervision of the Head of CVT.  

Responsibilities:

• Understand the global Client Lifecycle Management (CLM) procedure of the Corporate Client segment (and/or local addendums)
• Perform assigned tasks as part of the on-boarding, regular and event-driven review, account opening, account closure as well as off-boarding of Corporate Clients
• Review and assess quality of initial (potential) client data provided by Client Owner(s) / Business Unit(s)
• Perform validation of completeness and accuracy of mandatory KYC documentation and information provided by Client Owner(s) / Business Unit(s)
• Verify information and documentation provided by the Client Owner(s) / Business Unit(s) including but not limited to client’s identity, Beneficial Ownership and Bearer share information
• Track and follow-up on documentation deficiencies and perform escalations of any non-receipt of documentation in a timely manner
• Conduct screening on clients, beneficial owners, associated parties, legal representatives, authorized signers/traders and others as defined by the CLM procedures
• Perform disposition of screening results; inquire further information and perform escalations as required
• Perform adverse news screenings and disposition of results; inquire further information and perform escalations as required
• Ensure discrepancies that arise between the information obtained from the customer and the information that is obtained during the verification process are properly resolve in cooperation with Compliance prior finalization of on-boarding /review
• Determine the Customer Risk Rating (CRR) based on global CRR methodology owned by Compliance
• Perform manual overrides of calculated Customer Risk Rating as authorized by Compliance
• Ensure that the appropriate level of Due Diligence is applied to the Client at onboarding and review
• Provide support in account opening and account closure
• Ensure Client Data elements and performed Due Diligence are properly captured/documented in appropriate CLM systems
• Process any changes to client’s KYC data upon receipt and ensure proper documentation of performance
• Liaise with Client Owner(s) and Compliance to clarify questions and resolve issues as they arise
• Escalate issues to Head of CVT and seek for guidance as required
• Review, investigate, communicate and escalate if required any issues identified during the KYC process
• Support initiatives related to changes in the regulatory landscape, system enhancements or updates
• Provide support in potential remediation reviews
• Miscellaneous responsibilities as required

Experience:

• College degree in a business-related discipline or similar education, such as completed apprenticeship / training in the financial industry or similar education
• KYC / Compliance Certification preferred
• Professional experience in Client On-boarding operations and Anti-Money Laundering functions at a large financial institution
• Working experience in an international environment is a plus
• Advanced knowledge of Financial Crime prevention and Know Your Customer requirements
• Ability to review and understand business and legal documents required for the KYC process
• Experience in conducting screenings and handling of potential hits to adverse news, designated sanctions targets and prohibited persons lists
• Excellent analytical, oral and written communication skills
• Strong attention to detail required
• Advanced time management skills and ability to execute tasks within tight deadlines
• Ability to work independently or with limited guidance and seek for advice proactively
• Proficient use of MS Office Suite

Job Description:

• Perform customer due diligence, enhance due diligence and customer risk rating processes
• Multi-task and communicate effectively with Front Line Units and other LCD personnel
• Escalate key matters timely to the accountable and/or responsible person(s)
• Consistently produce high quality KYC customer files while maintaining expected daily output
• Maintain subject matter expertise of applicable KYC compliance requirements
• Perform quality control of KYC files during the life cycle of customers inclusive of onboarding, periodic, and trigger based reviews

Job Requirement:

• Bachelor’s degree is required
• Minimum 2 years’ relevant experience is required
• Detailed oriented and organized with proven ability to multi-task and communicate effectively with all levels of stakeholders
• Microsoft Office (e.g. Word, Excel, PowerPoint) is required
• Fluency in Mandarin, Chinese is preferred

Job Description:  

• Review and approve EDD dispositions submitted by the analysts of new and existing high-risk customers reviews.
• Analyze and review analysts EDD cases of personal / business information documents and external
• Responsible for performing the review and approval of analysts KYC processing of New High-Risk Accounts
• Conduct EDD reviews as warranted on periodic cases for High-risk customers via analyzing account transactions during a 12 month period
• Conduct QC of KYC/EDD Files, lead both CIP and EDD teams to be aligned with industry’s best practices.
• Represent the team in internal and external reviews inclusive of collection of testing evidence.
• Define and monitor operations metrics

Job Requirements

• Approx. 8 years’ experience

Job Details:

• Perform all necessary tasks to ensure all existing corporate and entity accounts are within regulatory guidelines established by Compliance Department procedures
• Use online “Cerved” Italian Chamber of Commerce database for control
• Scan and report information obtained from World Check, OFAC & negative news and provide disposition on all findings
• Conduct research through other information sources such as Dun & Bradstreet and other appropriate/designated sources
• Analyze transaction statistics sourced from the bank’s internal banking system (SIRE AS400), totals and volume of account activity
• Verify supporting identification documents for signatories found in the Credit/Legal files
• Review, update “repaper” existing corporate entities for submission to Account Officer for review and approval for subsequent delivery to the Compliance Department
• Send Request for Information (RFI) to Account Officers/or Assistants to obtain current or missing documentation in accordance with the banks procedures
• Adhere to/completion of AML/OFAC controls including monitoring for “red flags” and referring to Compliance Department as needed
• Provide training to department staff as required
• Act as back-up for other functions in the department under the direction of the supervisor

Primary responsibility:

• Liaise with Business Department relationship managers to review periodic KYC review and new customer onboarding.
• Participate in the relevant remediation project to perform quality check for submitted KYC profiles.
• Participate in team brainstorm to maintain, implement and further enhance the KYC procedure and customer risk scoring methodology.
• Assist with addressing internal audits and regulatory exams inquiries.
• Manage special projects as required.

Knowledge/Skill Requirements:

• Bachelor’s degree in finance, related field or equivalent experience.
• Working experience with BSA/AML, CIP/KYC, USA Patriot Act and OFAC as well as other relevant BSA/AML laws and regulations.
• At minimum 5 years of AML/KYC/CDD/EDD related working experience.
• Working experience with correspondent banking is preferred.
• Working experience from large U.S. or foreign banks is preferred.
• Solid knowledge in commercial banking products/services.
• Excellent problem solving, oral, and written communication skills.
• Great team player and self-starter.
• CAMS certified a plus.