Summary
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Deutsche Bank (DB) is committed to the highest standards of Anti-Money Laundering (AML), Sanctions & Embargoes, Anti-Fraud, Bribery and Corruption (AFBC) and wider Financial Crime (collectively referred to as Anti Financial Crime) prevention. The Management and all employees are required to adhere to these standards to prevent DB and our reputation from those who may intend to use our products and services for money laundering, bribery, corruption, fraud and/or Terrorist Financing (TF) purposes.
DB Group will examine its Anti-Financial Crime (AFC) strategies, goals and objectives on an ongoing basis and maintain an effective program for DB’s business that reflects the best practices for a diversified, global financial services provider.
The AFCO function is responsible for the AML, CTF, Sanctions & Embargoes, Anti-Fraud, Bribery and Corruption (AFBC) activities in the jurisdiction where relevant.
The AFCO will support Country Head of Compliance and AFC (Country Head) in ensuring 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 AFCO is also responsible to support 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.
Position Specific Responsibilities and Accountabilities
Anti-Money Laundering (AML)
· Maintain 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.
· Discharging the responsibilities of AFC as set out under global AML and 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 & Embargoes
· Monitoring local regulatory sanctions developments and notifying relevant changes and specifications to Country AFC Officer and 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 Bribery & Corruption
· 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 regional ABC team will assess if further regional support is required in delivery of local anti-bribery & corruption responsibilities. The regional ABC team will retain the lead in reviewing risks associated with certain ABC functions, specifically review of connected hire candidates and Business Development Consultants risk assessment per Policy, they will involve the local AFCO as it impacts their location.
Transaction Monitoring
· Perform AML monitoring of assigned businesses or jurisdictions.
· Investigate cases and associated transactions which escalated to local AFCO and identify potential areas of risk (financial, reputational, and regulatory) within the transactions and associated client relationship review.
AML Regulatory Reporting
· Support Country Head in ensuring timely submission of all AML regulatory reporting.
Others
· Provide input for MI reports requested by Global AFC, Head of Compliance and Anti-Financial Crime, Country AFC Officer or the AFC reporting function.
· Implement any Governance related controls, processes and procedures as directed by the AFC Governance function
· Ensure the local implementation of any country, regional or global AFC projects and programs in conjunction with the relevant regional leads
· Advise 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 Country Head of AFC.
· Assess the conformity of internal policies and procedures, systems and controls with relevant regulatory obligations and DB Group standards.
· Ensure timely delivery of the local AFC Risk Assessment in the country.
· Support Country Head to provide AFC advice in the change management process including but not limited to the New Product Approval (NPA) and Vendor Risk Management (VRM) Process.
· Support Country Head to provide appropriate training to staff and arranging training by other regional leads for Sanctions & Embargoes, AFBC
· Other relevant tasks assigned from time to time.
Requirements
· Have experiences on Anti Financial Crimes, Anti Money Laundering, Know Your Client or Compliance, Risks or other Control Functions are preferred.
· Understanding of banking products, process, anti-financial crimes risk and controls.
· Analytical thinking, risk and control oriented.
· Confident and articulate partner to multiple functions.
· Ability to work independently and prioritize tasks under pressure
· F luent in verbal and written English
Education/ Qualifications
· Bachelor’s Degree Holder
· Relevant AML or related certifications
Our values define the working environment we strive to create – diverse, supportive and welcoming of different views. We embrace a culture reflecting a variety of perspectives, insights and backgrounds to drive innovation. We build talented and diverse teams to drive business results and encourage our people to develop to their full potential. Talk to us about flexible work arrangements and other initiatives we offer.
We promote good working relationships and encourage high standards of conduct and work performance. We welcome applications from talented people from all cultures, countries, races, genders, sexual orientations, disabilities, beliefs and generations and are committed to providing a working environment free from harassment, discrimination and retaliation.
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