STRATEGIC INTENT
Ensure NDB’s compliance with all processes, procedures, policies and statutory requirements.
PRIMARY PURPOSE OF THE ROLE
To develop, maintain and implement a comprehensive risk management, compliance, and financial crime framework (covering strategy, policy, processes, procedures, measures, standards, objectives and governance.
As the Anti-Money Laundering Officer (AMLCO), develop, maintain and implement a comprehensive AML/CFT framework (covering strategy, policy, processes, procedures, measures, standards, objectives and governance)
To ensure comprehensive identification of all key relevant risks in all departments and provide guidance on mitigation to ensure compliance that align to relevant risk frameworks and policies and minimize losses.
KEY PERFORMANCE AREAS
COMPLIANCE FRAMEWORK
- Develop, maintain, and implement the risk & compliance frameworks (covering strategy, policy, processes, procedures, measures, standards, objectives, and governance).
RISK MATURITY
- Drive and enhance the risk maturity in NDB.
COMPLIANCE MONITORING PLAN
- Develop and implement monitoring and testing coverage plans to ensure compliance and the embedding of the compliance framework.
CONFORMANCE REVIEWS AND CONTROL TESTING
- Plan and deliver conformance reviews across all entities and address focus areas. Risk based approach, customer due diligence, enhanced due diligence, KYC, PEP management, sanctions.
PEP/PIP MANAGEMENT
- Develop and monitor the plans for on-boarding of PEP/PIP clients includes developing KYC standards/procedures for PEP/PIP approval of onboarding and annual reviews.
REPORTING AND MITIGATION
- Report findings on all compliance, AML/CFT breaches to the relevant management, committees, and regulators.
- Prepare and submit internal reports to the relevant forums (exco, Board)
- Prepare and submit the required periodic reports to BoB, FIA, NBFIRA and other regulatory authorities.
COMPLIANCE AND FRAMEWORK
- Lead and manage the compliance & AML teams in accordance with the performance management framework.
DISPENSATION REQUESTS
- Facilitate any dispensation requests against policies & standards.
REGULATORY CHANGE MANAGEMENT
- Monitor developments to the regulatory landscape and regulatory changes and international best practice to ensure that changes are appropriately assessed and incorporated in the frameworks and socialised with NDB.
TRAINING AND AWARENESS
- Develop and implement appropriate and mandatory risk, compliance & AML training thus ensuring that training and awareness of regulatory requirements is conducted.
- Monitor training outcomes and identify staff who need training.
RISK ADVISORY
- Provide specialist advise on risk, compliance & AML risks to business and responding to both internal & external enquiries and advising accordingly.
- Provide specialist risk, compliance & AML support to new products, channels and services (risk assessments).
- Embedding risk & tools (Key risk indicators, audit findings management, risk management plans, regulatory universe etc)
- Provide specialist support to finance/procurement on conducting due diligence for supplier on-boarding.
LOSS MONITORING
- Implement operational loss policies and processes including incident management processes.
STAKEHOLDER ENGAGEMENT AND MANAGEMENT
- Attend external risk, compliance and AML forums
- Establish and maintain stakeholder relationships including Police, FIA, BoB, Board etc.
- Plan and manage visits to regulators to maintain cordial relationships.
ANTI – MONEY LAUNDERING COMPLIANCE
- Fulfil the regulated role of designated AMLCO as described under the FIA Act
- Develop, maintain & implement AML/CFT strategy.
- Provide oversight on the regulated roles of AMLCO as described in FIA Act
- Provide oversight with respect to the development and implementation of AML/CFT monitoring plans to ensure that NDB complies with AML/CFT requirements.
- Provide oversight with respect to the development and implementation of the AML/CFT monitoring plans to ensure that NDB complies with AML/CFT requirements.
- Develop, deliver, and deploy of AML surveillance solutions to address and manage AML/CFT risks.
- Develop and maintain sanctions screening processes and procedures.
- Receive STR reports from staff and clients, conduct investigations, and prepare reports to FIA.
- Maintain system rules for the AML system. Set up user and monitor users.
- Provide oversight to ensure that NDB maintains transaction records as well as STR & CTR records as per regulatory requirements.
- Develop processes to ensure that the annual review of high-risk clients (PEPs/PIPs) is conducted and that customer records are updated every 2-3 years.
QUALIFICATIONS & EXPERIENCE
- Minimum Qualification – Bachelor of Risk Management, Bachelor of Commerce Degree or any relevant degree
- Additional Knowledge – Botswana regulations eg NBFIRA regulations, AML, Data Protection Act
- Experience – 10 years’ relevant experience in a risk management function, preferably in a financial institution of which 5 should be at a senior management level