Group FCC Systems Custodian

Job Title: Group FCC Systems Custodian

Department: Group Compliance

1. Job Purpose:

• Manage (including insurance of proper governance) of the FCC Systems, to include systems upgrade projects, implement new functionalities with the support of vendors and internal teams, support, external, internal Audit for FCC Systems and other relevant FCC Systems initiatives.
• Responsible for Tuning activities (including testing) in relation to screening parameters/filter settings under Transactions Screening, Customer Screening, Transaction Monitoring and FATCA Systems.
• Responsible for FCC Systems Governance, related processes and documentation.

2. Dimensions of role (i.e., budgets managed, number of staff):

Financial (Revenue, Expenses, Budgets etc.) Non-Financial (size of team, geographical coverage, time horizon of main decisions, etc.) 
Role will interact with the Compliance and MLRO teams across all Group Units

3. Principal Responsibilities, Accountabilities and Deliverables of Role:

• Serve as the primary Subject Matter Experts (SME) for GFCC Systems to the Compliance Teams in Bank ABC Group-Wide.  
• Accountable for ensuring ongoing maintenance of GFCC Systems
• Responsible for ensuring that the necessary automated processes within GFCC Systems are scheduled, maintained and executed by Group IT.
• Accountable for identifying, communicating, raising system related defects and/or issues with vendors and ensuring resolution.
• Serve as primary SME for MI Reports.
• Accountable for managing the upgrades of GFCC Systems and ensuring the implementation of new GFCC System releases/capabilities. This includes:
  -Project planning
  -Coordinating with IT, Vendors and Group-Units Stakeholders, to ensure that all involved parties have completed their task on time and in a successful manner
  -Coordinating GFCC Systems updates, timings and their related business processes, to include the development of release test plans, detailed systems implementation, testing and obtaining related signoffs.
• Gather the requirements from Group Units, prepare the business requirements documents (BRDs) and implement required functionalities within the FCC Systems.
• Ensure the timely implementation of GFCC Systems functionalities, to include any new functionalities should be thoroughly tested in UAT, before implementation into Production.
• Responsible for ensuring that GFCC Systems thresholds and parameters are reviewed annually and optimized to meet the needs of the entire Group.
• Responsible for working with GFCC and ABC Units in assessing the systems related impact of new regulatory requirements and/or developments and schedule the deployment of these changes.
• Review and advise the GFCC Systems Management Working Group on issues and proposed changes regarding GFCC systems.
• Responsible for supporting ABC Units in the management of Audits and Regulatory initiatives related to GFCC Systems.
• Responsible for building, enhance and operationalize screening business rules, monitoring scenario, CRAM rules and MI reports. 
• Provide training to ABC Units on the functionality and/or upgrades of GFCC Systems. 
• Demonstrate deep knowledge of IT Systems and technical skills.
• Support to completion any system upgrades/projects within Group-Wide FCC Systems on time.
• Management of Sanction Lists, responsible for any necessary changes in Screening Properties Files.
• Supporting Group IT in investigating any batch issues and process logs.
• Performing detailed analysis in DB/SQL and support Group IT to generate new reports and metrics.
• Supporting GFCC FIU to do the SQA (independent reviews) catering for any FCC Systems upgrades.
• Performing detailed analysis of the FATCA scenarios and related documentation.
• Managing SironTCR Tuning projects and initiatives, allowing a smooth implementation of any amended mapping and scenarios across all units.
• Supporting Group-Wide FCC Systems integration, queries and issues.

General:

• Provide timely, practical, value-added FCC Advisory to the Business and Functional Units, covering Group-Wide Compliance Teams under Policies ownership and/or geographic oversight, where applicable.
• Support the Bank Group-Wide in the development and implementation of the FCC Frameworks, Policies and Procedures, in partnership with the Group Document Owners.
• Demonstrate pro-active identification and management of key Regulatory Risks and issues.
• Self-identification of Compliance related Audit issues.
• Closure of outstanding Audit issues within stipulated time and/or as agreed with Internal Audit.
• Support, oversight and facilitate effective functioning of FCC Systems Group-Wide, where applicable. 

4. Risk, Compliance & Business Continuity:

• At all times, act with due care, skill, and diligence to ensure compliance with Bank ABC’s risk culture, policies and procedures, Code of Conduct and Values.
• Escalate risk and compliance issues in a timely manner to your line manager and ensure that all mandatory training is completed to schedule.
• Escalate to MLRO in a timely manner any knowledge or suspicion of financial crime, providing all pertinent facts and assistance where required for further investigation.
• Participate in exercises to rehearse the banks response to an emergency (i.e., evacuation exercises and Business Continuity tests)

6. Main Contacts:

Group FCC 
Heads of Compliance 
Group IT
GFCC Vendors:

• MTF (Siron)
• EastNets
• FICO Tonbellar (SironACM)

Contact Group

• Group FCC
• Unit Head of Compliance
• Group IT
• Vendors:
  -IMTF (Siron)
  -EastNets (SafeWatch)
  -Fenergo (FenX)

Internal / External

• Internal
• Internal
• Internal
• External

Purpose

• Fulfil daily responsibilities

Frequency

• Daily / as required
• Daily / as required
• Daily / as required
• Periodic / as required

7. Job Requirements:

Knowledge:

• Knowledge and 5+ years of experience implementing FCC Systems (Sanctions and Transaction Monitoring)
• Sound knowledge of mainstream Sanctions Screening Systems 
• Sound knowledge of mainstream Transaction Monitoring Systems 
• Sound knowledge of leading validation service providers 
• Knowledge of designing, implementing, and validating quantitative models
• Exposure to Artificial Intelligence and/or Machine Learning models
• Project Management

Education / Certifications:

• Computer Science degree or equivalent in related work experience
• ACAMS qualified preferred but not essential

Experience:

• Relevant Banking experience preferably in Compliance and/or Risk Management
• Experience in AML and Sanctions preferred
• Experience of participating in regulatory inspections relating to FCC Systems
• Exposure to working at Group level
• Experience with risk models (customers, country, product and industry)  
• Experience of implementing a multi-entity FCC System 

Personal Attributes:

• Good communicator, analytical skills and highly collaborative

8. Version Tracking:
Version: v4
Prepared by: Bruno Costa
First Review by: Head FCC Systems
Second Review by: Group Head of Financial Crime Compliance