C&AFC – Anti-Financial Crime Compliance Manager - AVP

Details of the Division and Team:

The AFC manager is responsible for the AML, CTF, Sanctions & Embargoes, Anti-Fraud & Investigations (AFI) and ABC in the jurisdiction.

The AFC manager ensures that all relevant AFC policies, procedures, systems and controls are implemented effectively, all AFC-relevant legal, regulatory and DB Group requirements are met and any AFC-related risks are appropriately addressed and mitigated.

The AFC manager is responsible for the identification, assessment, advice on, monitoring, control and reporting on the AFC laws, rules and standards relevant to the DB activities in their respective jurisdiction.

The AFC manager is the direct point of contact for DB staff in AFC matters, in particular in terms of whistle-blowing, employee reliability or concerns raised in a confidential environment when improper or illegal AFC related activities are suspected.

What we will offer you: 

A healthy, engaged and well-supported workforce is better equipped to do their best work and, more importantly, enjoy their lives inside and outside the workplace. That’s why we are committed to providing an environment with your development and wellbeing at its center.

You can expect:

• Corporate Group Insurance – premium borne by company

• Medical Checkup – cost borne by company (annual/ biannual basis subject to the employee’s preference)

• Remote working arrangement called “Future of Work”

• EAP – free and confidential counseling, online work-life resources

Your key responsibilities:

• The AFC manager has decision-making authority over the Business on AFC related matters.

• The AFC manager has unrestricted access to all information, data, records and systems in the Bank he/she deems necessary to fulfil its function.

• Advising on and ensuring implementation of AFC policies and procedures whereas involvement in ABC and AFI policies depends on the availability of headcount in the location and if none, this will be assisted by the respective regional team. 

• Advising on the impact of new AFC related internal and external rules and ensuring that local guidelines and procedures are in line and reflect German and local laws / regulations. Escalate exceptions to the Regional Head of AFC.

• Assessing the conformity of internal policies and procedures, systems and controls with relevant regulatory obligations and DB Group standards.

• Being primary point of contact for AFC matters with competent regulatory, law enforcement or other public authorities in their jurisdiction in conjunction with the respective regional heads.

• Reporting and liaising with Regional Head of AFC and other AFC Senior Management to ensure appropriate reporting and escalation of issues and/or incidents. Contributing to DB AFC Function as a whole by sharing knowledge and best practices with AFC Officers of the other Businesses and entities and other AFC managers including measures to deal with new trends and techniques of money laundering and terrorist financing in response to the development of electronic financial technology and new products. Contribute to the development of AFC methodologies by cooperating with other disciplines like Compliance, Legal, Audit and Operational Risk Management.

• Ensuring timely delivery of the local AFC Risk Assessment in the country leveraging off regional assessments performed for ABC and AFI topics.

• Providing AFC advice in the change management process including but not limited to the New Product Approval (NPA) and Vendor Risk Management (VRM) Process.

• Helping maintain an AFC compliance staff awareness culture by providing appropriate training to staff and arranging training by other regional leads for Sanctions & Embargoes, ABC and AFI. Oversight of local Training and ensure that AFC Training requirements are met in conjunction with the aforementioned leads.

• Developing and maintaining the AFC related Internal Control Framework under advice from Regional AFC Risks & Controls to ensure adequate monitoring and control measures are implemented, report on any findings and advise management on remedial actions to take.

• Complying with the requirements set by the AFC Global Controls Programme. Develop and carry out adequate controls to ensure that all applicable legal and regulatory AFC requirements are being adhered to in their jurisdiction

• Disseminating information or documents related to foreign exchange transaction when the local regulator (KoFIU) makes a written request for such information or documents for the purpose of analysing specific financial transaction information

• Exchanging information with the local regulator (KoFIU) on the operation of the internal reporting system regarding STR and CTR and how it is examined and improved is requested

AML: Maintaining especially an adequate Internal Control Framework for Unusual and/or Suspicious Transactions in terms of organization, administration systems and controls to ensure properly and timely detection, investigation and reporting of unusual and/or suspicious transactions or activities to competent authorities in compliance with applicable rules. 

• Implementing adequate monitoring – research /surveillance tools.

• Discharging the responsibilities of AFC as set out under global KYC policies for divisions present in the jurisdiction.

• Deciding on new or existing clients that are escalated, or decide to escalate further.

• Tracking and following-up on the conditions that have been imposed as part of the KYC approval.

• Following-up with the Business on status of Regular Reviews and obtain relevant MIS from the Business.

Sanctions: Monitoring local regulatory sanctions developments and notifying relevant changes and specifications to the Regional Head of Sanctions.

• Discharging the responsibilities of the Group Embargo Office locally as set out in the Group Embargo Policy and in the Special Risk Country Policy, in particular, ensuring implementation of applicable sanctions requirements on a country level.

Anti-Fraud: AFC manager locally must assume and promote AFC’s responsibility for anti-fraud in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional AFI teams.

• The AFC MANAGER must refer all fraud matters to the relevant Regional Head of AF&I who will provide support in delivery against these anti-fraud responsibilities remotely from a regional level.

Anti-Bribery & Corruption: AFC manager locally must assume and promote AFC’s responsibility for anti-bribery & corruption in country (including advisory, policy, training, monitoring, investigation etc), either directly or as the liaison with regional ABC teams.

• The AFC manager must refer all bribery and corruption matters to the relevant Regional Head of ABC who will provide support in delivery against these anti-bribery & corruption responsibilities remotely from a regional level.

• Ensuring that AFC Employee Reliability Requirements are met.

• Ensuring that local record keeping processes are in alignment with the AFC related legislative, regulatory and internal requirements.

• Providing input for MI reports requested by Global AFC or the AFC reporting function.

• Implementing any Governance related controls, processes and procedures as directed by the AFC Governance function.

• Ensuring the local implementation of any country, regional or global AFC projects and programs in conjunction with the relevant regional leads.   

Your skills and experience:

• Minimum 5 years’ experience in Compliance, AFC, AML, or KYC related preferred

• Excellent communication skills and analytical thinking required

• Banking and financial sector experience required

• Any AML related degrees or certificates preferred

• Strong regulatory knowledge.

• Able to motivate employees and a team player.

• Resilience to manage internal as well as external audits.

How we’ll support you: 

• Flexible working to assist you balance your personal priorities

• Coaching and support from experts in your team

• A culture of continuous learning to aid progression

• A range of flexible benefits that you can tailor to suit your needs

• Training and development to help you excel in your career

About us and our teams:

Deutsche Bank is the leading German bank with strong European roots and a global network. click here  to see what we do.

Deutsche Bank & Diversity

We strive for a culture in which we are empowered to excel together every day. This includes acting responsibly, thinking commercially, taking initiative and working collaboratively.

Together we share and celebrate the successes of our people. Together we are Deutsche Bank Group.

We welcome applications from all people and promote a positive, fair and inclusive work environment.