Head of Financial Crime Compliance Wholesale Banking in Brussel

Head of Financial Crime Compliance Wholesale Belgium (FCC WB)

Role & work environment

Financial Crime Compliance Wholesale Belgium (FCC WB) team within the compliance department is the second line of defence function supporting the wholesale segment in Belgium for the purpose of managing Financial Crime Compliance (FCC) risks.

The team of Wholesale Banking FCC specialists (advisors) is dedicated to support the wholesale business in complying with FCC policies and regulations in line with the Compliance Risk Management Charter by performing horizon scans, maintaining the policy framework, supporting & challenging risk assessments, delivering advices, assuring training & awareness, tracking issues and escalating where and when needed. At the same time it looks for global alignment and uniformity in approach in order to contribute to efficient KYC-processes and a flawless client experience. The team is working together based on knowledge and expertise, as well as the skill set needed to best perform the job.

You report hierarchically to the Head of Financial Crime Compliance, being the Anti-Money Laundering (AML) Compliance Manager of ING Belgium.

Key responsibilities

As head of the FCC WB team you manage, motivate and coach a team of experts, which is the key and expert channel for advice, training, translating (external) developments to the wholesale banking environment as well as communicating and sharing of best practices related to the FCC wholesale domain.

As a content matter expert and decision maker you are also responsible for taking final decisions on specific files as well proposed solutions being implemented. 

Together with the head of FCC Retail and the head of FCC Governance and control, you are, jointly responsible in managing and monitoring risks in close cooperation with the Anti-Money Laundering Compliance Manager on Anti-Money Laundering (AML), Economic and Financial Sanctions including Export Controls and Proliferation Financing which translates to the following (non-exhaustive) overview of activities, which you will execute:

•             Lead a team of FCC WB advisors:

o             Steering of the compliance activities in the FCC wholesale banking area with the help of a team of compliance advisors;

o             Ensure the continuous development of compliance knowledge and expertise within the FCC WB team and contribute to the same within the wider ING compliance community;

o             Create a productive and constructive collaboration and exchanges within the team as well as with other compliance teams (e.g. FCC Retail team, FCC Governance & Control team, Quality Assurance team);

o             Support the team members in the execution of their activities; take as a content matter expert final decision when needed;

o             Cover all HR related activities, including performance management;

o             Contribute to the dynamic planning.

•             Set together with the team solid, future proof compliance standards and advice & steer on these standards:

o             Maintaining expertise and in depth subject knowledge and understanding of good practice and procedures in the FCC domain (continuous development) in Wholesale banking;

o             Point of escalation and coordination for Wholesale Belgium including financial institutions, specifically:

Analysis, challenging and advice on customer due diligence escalations triggered by:

•             new client Onboarding;

•             client reviews (periodic, event driven) including transaction analysis;

•             Offboarding;

•             Waivers.

Analysis, decisioning and follow through on FCC alert escalations triggered by:

•             Pre transactions screening;

•             Name screening (PEP);

•             Negative News Screening.

Advice on flagged corporate lending and trade finance transactions;

Transaction monitoring analyses, advice and investigation related to correspondent banking activities.

o             Support the business, FCC Belgium and Corporate FCC function in maintaining the wholesale and correspondent banking FCC control framework by translating regulations and requirements to practical implementable policies, guidelines, instructions or solutions;

o             Advising on risk appetite setting and translation thereof in compliance related processes;

o             Pro-actively oversee and advice (partner) with our Belgian and global wholesale businesses on the embedding of the FCC controls within the wholesale/correspondent banking domain by analysing and formulating advices on the compliance risks of products, processes or projects or delivering support and challenge when needed any risk assessment or mitigation (e.g. participating SIRA). Work from the basis of what’s possible within the confines of law and regulations and at the same time enabling the business in achieving sustainable growth. Proceed to instructions or escalation if advices are not considered;

o             Cooperate with Global and WB FCC on actions applicable to Belgium. This includes, jointly with the WB MLRO team, the execution of the annual counterparty visit schedule for correspondent banking, as well as supervise all outsources functions related to the correspondent banking activity;

o             Assure in close cooperation with the wholesale business that all identified FCC risks are correctly registered in I-Risk and follow-up the correct closure of the mitigating actions.  Pro-actively inform compliance management on the evolution of the FCC compliance risk management in your domain;

o             In close collaboration with colleagues of other compliance teams, promote/enhance the knowledge and awareness with regards to FCC within the organisation by a.o. liaising with 1st line of defence (senior) management and contribute to the drafting and/or implementation of the annual compliance  training plan.

•             Pro-active Report and steer improvements:

o             Identify key areas for improvement and provide support and guidance to implement good practice;

o             Drive the implementation of automated process, robotics or data analytics techniques in order to maintain the efficiency of the FCC wholesale compliance related processes and tools;

o             Participate in programs, internal and external workgroups by coordinating, providing input, defending his/ her position, challenging the discussions and communicating the output to the members of the team;

o             Providing clear and convincing compliance risk management reporting  in all its forms.

•             Seek for uniformity in approach by continuously aligning with the WB MLRO/FCC community and global functions;

•             Represent ING towards senior management and third parties (e.g. regulator, febelfin).

Key Competences

A colleague with a talent for taking it on and making it happen, enthusiasm for helping others to be successful and a knack for always being a step ahead. In other words, you strive to bring fresh ideas to life and embrace challenges in a fast changing and complex environment. You are a naturally collaborative person who listens and invests in others to achieve common goals. You love to challenge the status quo and are eager to propose creative solutions to problems.

As a Head of FCC WB you will also need:

•             A master degree in Law, Economics or equivalent in experience;

•             More than 10 years’ work experience in a control (compliance, financial control, audit, …) in a wholesale or correspondent banking world or equivalent;

•             Team manager experience (the job holder will manage a team of 5 - 10 experts);

•             A couple of years’ experience as compliance officer or in highly complex environments (matrix reporting organisations) is a plus;

•             Advanced knowledge on the industry trends and ever changing FCC compliance regulations & procedures;

•             A team player with strong interpersonal skills who is able to build effective working team and relationships within a diversified and multicultural work environment;

•             Strong in written and spoken English (and French or Dutch);

•             Good analytical skills, interest for data (analysis) and the way to process them, as well as a keen eye for detail;

•             Very good knowledge of Excel, Powerpoint, knowledge of other software application is a plus;

•             Able to use different communication styles fitting with the need of the (internal) customer, both verbally and written;

•             Being able to quickly integrate new concepts, procedures, modifications in the organisation or methodologies;

•             Good skill set in the areas of personal effectiveness (i.e. autonomy, team spirit, courage and self-confidence, problem solving & result oriented by delivering as promised, “hands-on”, good written and oral communication, capable to work in changing circumstances, customer focus and investigative & learning ability).