Senior Financial Crime Risk Oversight Analyst
The Senior Financial Crime Risk Oversight Analyst provides a range of research, guidance, and business oversight to assigned portfolio, business, or function to ensure that strong AML / ATF / Sanctions / ABAC controls and processes are in effect to mitigate inherent associated risks. Contributes to the development and implementation of AML / ATF / Sanctions / ABAC Compliance programs related to all aspects of AML and ATF laws.
The U.S. FCRM Governance and Regulatory Response group (the FCRM group for this position) is responsible for developing and overseeing program-wide methodologies and frameworks for the purposes of financial crime risk management. This includes setting and managing standards for program-wide governance and escalation, executing risk assessments, testing, quality assurance and training programs. The team also produces program materials for the purposes of both ongoing supervision meetings with the bank's regulators and board committee meetings associated with financial crimes risk management, including information notifying board directors of suspicious activity reported by the bank.
Financial Crimes Risk Management (FCRM) has the following mandate :
- Creating and executing the US FCRM policies, standards, and thresholds, in compliance with U.S. Laws, Rules, and Regulations, and determining the US FCRM Risk Appetite within the Enterprise FCRM guardrails
- Performing the AML Risk Assessment Program, with US driven ML requirements, designed to detect, deter, and prevent these activities from occurring at the Bank in compliance with US laws, rules and regulations
- Maintaining the US FCRM Program current with US regulatory guidance and expectations (customers and business relationships, products and distribution channels, geographic locations of activity, other prescribed factors, and any other relevant factors) and any regulatory changes, emerging issues, and trends in the external environment.
- Reviewing, evaluating, and actioning when to demarket (exit) a customer relationship due to money laundering, terrorist financing, sanctions, or bribery / corruption concerns, including those identified through suspicious activities or transactions or similar reporting, AML investigations, or other sources that indicate significant heightened risk
- Implementing, executing, and monitoring an effective US FCRM Program in compliance with applicable laws and regulations in all Business Lines, as appropriate, inclusive of the US FCRM's specialized oversight and execution of risk and control activities
- Identifying and submitting reporting / escalations to TDBUSH, TDGUS Boards / Board Committees and / or regulators when material AML / ATF regulatory and compliance issues occur
Depth & Scope :
Specialist level professional role requiring in-depth knowledge / expertise in AML / ATF / Sanctions / ABAC and working knowledge of broader related areasProvides advanced analysis and / or specialized reporting to support business partners, functional areas, or centers of expertiseProvides AML / ATF / Sanctions / ABAC advice to a business as FCRM representative on a straightforward project or change initiativeIntegrates the broader organizational context into advice and solutions within the AML / ATF / Sanctions / ABAC areaUnderstands the industry, competition and the factors that differentiate the organizationLeads projects of moderately to complex risks and resource requirements; may lead end-to-end processes or functional programsContact for business management, external / internal auditors, dealing with non-routine informationRecommends and implements solutions within own area of responsibilityMay need to coordinate / integrate work with other areas as neededIdentifies and leads problem resolution for complex requirements related issues at all levelsEducation & Experience :
Undergraduate Degree5+ years of experiencePreferred Skills :
Experience in the execution of risk assessments and providing credible challenge in response to stakeholder self-assessments and data validation; specific experience with ABAC regulations and risk assessments is a plus.Experience documenting processes and corrective issues / action plans.Good communication and interpersonal skillsAbility to coordinate across multiple management levels, jurisdictions, business lines and support functions to drive results and meet timely deadlines.Proficiency with standard computer applications including Word, Excel, and PowerPoint.Customer Accountabilities :
Provides guidance on day-to-day AML / ATF / Sanctions / ABAC matters affecting the business based on regulatory compliance requirements and industry best practice, including, but not limited to, customer identification and due diligence, enhanced due diligence, policy, governance, training and / or compliance assurance and testing.Provides / Executes skilled AML / ATF / Sanctions / ABAC research, risk assessment, reporting and / or analytical support in a timely mannerAssists / Partners in the development and implementation of appropriate AML / ATF / Sanctions / ABAC policies, processes, and controlsSupports the facilitation of periodic AML / ATF / Sanctions / ABAC risk and self-assessment activities for designated business using TD's enterprise AML / ATF / Sanctions / ABAC risk assessment frameworkEnsures that assessments (monitoring, risk assessment etc.) are completed and communicated in a dynamic and timely fashionHandles matters escalated for the identification of suspicious activity, or identified through the Enhanced Due Diligence process in accordance with established processes and protocols, and assists in ensuring that the business takes appropriate steps to address those activities and customersWorks collaboratively with business and control partners within the organizationPrepares and delivers management reporting necessary to ensure accurate and thorough measurement of the risk factors present in various productsProactively identifies matters which require additional attention and presents objective and independent opinion on the adequacy of AML / ATF / Sanctions / ABAC processes and controls and opportunities to enhance those controlsPresents objective and independent opinions on the adequacy of AML / ATF / Sanctions / ABAC processes and controls in accordance with regulatory and internal requirements, and liaises with the appropriate FCRM and business partners to resolveShareholder Accountabilities :
Reviews and provides feedback on business line policies and proceduresAnalyzes AML / ATF / Sanctions / ABAC compliance requirements and ensures they are properly written into requirements for business projects and approved at the appropriate levelsConsistently exercises discretion in managing correspondence, information, and all matters of confidentiality; escalates issues where appropriateAnalyzes risk exposure characteristics for assigned portfolio in accordance with established processes or procedures, making recommendations for enhancements or changes based on changes in the regulatory environment or business processesWorks with business management, and with internal and external business partners (e.g., Internal Audit, external consultants) to respond to regulatory requests, findings, audits and / or examinationsKeeps current on emerging issues, trends, and evolving regulatory requirements in the AML / ATF / Sanctions / ABAC industry and assesses potential impactsCoordinates with other AML / ATF / Sanctions / ABAC partners and business compliance partners to ensure consistency in the application of AML / ATF / Sanctions / ABAC programs and standards across the enterpriseProtects the interests of the organization identifies and manages risks, and ensures the prompt analysis and escalation of non-standard, high-risk issues, monitoring to thorough resolutionAcquires and applies expertise in the AML / ATF / Sanctions / ABAC disciplines, providing basic guidance and direction to business and other FCRM partnersEmployee / Team Accountabilities :
Participates fully as a member of the team, supports a positive work environment that promotes service to the business, quality, innovation, and teamwork and ensures timely communication of issues / points of interestProvides thought leadership and / or industry knowledge for own area of expertise in own area and participate in knowledge transfer within the team and businessParticipates in personal performance management and development activities, including cross training within own teamContributes to team development of skills and capabilities through mentorship of others, by sharing knowledge and experiences and leveraging best practicesLeads, motivates and develops relationships with internal and external business partners / stakeholders to develop productive working relationshipsContributes to a fair, positive, and equitable environment that supports a diverse workforce