Vice President, FC Risk Models

Job Title: Vice President, FC Risk Models

Purpose of the role  

• The VP, FC Risk Models role sits in Group AML with responsibility for the design, implementation and maintenance of the three FC Risk Models:  Product Risk Assessment Model (PRAM), Financial Crime Country Risk Model (FCCRM) and/or Financial Crime Customer Risk Assessment Model (FCC-RAM).  The focus of this role will be specifically the FCCRM, including its implementation into the customer risk assessment and therefore supporting tasks in relation to the FCC-RAM.

In this role, you will:

Supports the model sponsor and model user community in:

• Design and implementation of the FCCRM and FCC-RAM in line with HSBC governance processes and policies
• Review of industry and regulatory developments, regulatory enforcement actions related to financial crime (in particular country risk), undertaking scheduled reviews of model methodology and aligning the models with key regulatory and industry guidance
• Represents the whole model user community for the use case, including all relevant legal entities and line of business markets
• As representative of the model sponsor and model user line of business stakeholders, participate in validating model design to ensure the model meets business requirements
• Inputs into and reviews artefacts/documentation as part of the model lifecycle
• Supports in the approval of model risk materiality ratings
• Support the completion of model related impact assessments on changes and enhancements. Identifying scope, requesting data and presentation of output.
• On behalf of model sponsor and as model user, perform check and challenge including sustainability of model methodology
• Management of the FC Risk Models Working Group to support planning of model development in line with the evolving regulatory landscape and promote and take accountability for the oversight, check and challenge, governance, risk assessment, support reporting and communication, that is directed towards setting up of a robust oversight framework
• Supporting model owner and model developer in Compliance Analytics in validation activities including SME input into the Expert Judgment Review process and the Independent Model Review (IMR) of the risk models
• Supporting development of the Transactions Monitoring Risk Assessment and Sanctions Product Risk Assessment and providing ongoing support across all FC Risk Models, where required
• Drafting of procedural documents
• Delivery of training on the risk models

Principal Accountabilities:  Key activities and decision-making areas           

Impact on the Business [COMPLETE 3-4 AREAS]

• Responsible for establishing and keeping up to date, the standards for maintaining an effective FC Risk Models framework, that supports all geographies and LoBs in HSBC.
• The role is expected to bring about a key, risk balanced approach while overseeing the Risk landscape and key risks for FC Risk models.
• Input to creation and development of the larger Global FC Risk Models Strategy, working closely with FC sub-functions, business, CCOs and Regional counterparts as appropriate
• The role will bring in the necessary direction that helps in maintaining a balance between risk (coverage) and commercial (effeciency) considerations.
• The role holder is expected to keep in close touch with the industry best practices and challenges within similar operating environments, that would support the bank in maintaining a sustainable, highly effective risk management oversight framework for the FC Risk Models function.
• Develop an ongoing oversight framework, that is geared to oversee, identify, check & challenge control owners in maintaining the Modelling landscape.
• Work closely with the business and FC, CCO, 1LoD and Regional teams to ensure that the function’s risk indicators are continually monitored and effectively reported.
• Support the overall AML goals and enhance the bank’s ability to deter, detect and protect against Financial crime risks.
• Provide advisory support to Control Owners, on Operational Risk matters.
• Provide SME guidance to FC & AML Senior Leadership, Global Businesses  and other related functions in support of maintianing a sustainable and efficient FC Risk Models framework.

Typical KPIs and Targets

• Established and maintained a clear and effective oversight framework on Monitoring risk landscape, spanning across geographies and LoBs
• Recommend decisions for approval by the Head of FC Risk Models and accepted by the Business / Other FC AML functions
• Clear, accurate and timely advice provided by the role holder on escalated monitoring matters, with specific regards to operational risk, risk appetitite, control library, Assessments of the FC Risk Models framework.

Customers / Stakeholders [COMPLETE 3-4 AREAS]

• Engaging with stakeholders within the business, including FC, Compliance Analytics and operational teams to further enhance the model and with Regional/Local FC representatives to provide SME guidance and support relating to the FC Risk models
• Providing support and guidance to 1LoD and 2LoD stakeholders for local implementation and maintenance of the risk models
• Providing detailed briefings and updates to Group Head of AML and other members of FC senior management, escalating material issues and concerns promptly
• Facilitating collaboration between FC Risk Steward teams and relevant stakeholders (eg. IT, Transformation, Analytics, Business, FC Detection etc) to appropriately escalate material incidents and other areas of concern
• Collaborating with Business, countries and regions, Assurance, Internal Audit (GIA) and IMR teams to review and resolve issues
• Fostering positive and professional working relationships with 1LoD and 2LoD, country and region stakeholders, Compliance and other stakeholders involved in or impacted by the risk models.
• Promoting a culture of partnership and collaboration, both within Risk & Compliance and across to other functions/stakeholders, responding to feedback from countries, regions and business.
• Liaising with GIA and external auditors related to the models, supporting execution of management action plans to address and close audit findings

Typical KPIs and Targets

• High quality succinct and clear communications while providing the Compliance view of the risk performance of FC Risk Models.
• Mature and balanced appreciation of commerical and risk considerations, while recommending optimization solutions to risk and control owners.
• Evidence of regular communications with the Business, and Regions
• Improved awareness of the Business and wider market operating environment.
• Positive upswing on risk management, as evidenced through a pre defined criteria with supporting metrics on KRIs etc.

Leadership & Teamwork [COMPLETE 3-4 AREAS]

• The role holder will provide support to the leadership and directional steer of the FC Risk Models team, as well as professionally sound guidance to the Regions and Global Businesses.
• As a member of the FC Risk Models team, foster positive and professional working relationships with the business, Global Compliance functions, and other managers throughout the Group.
• Promote an atmosphere of collaboration not competition, both within the function and across to other functions/ partners, responsive to suggestions from their areas, regions and businesses
• Motivate and assist with the development of an effective team through support and communication.
• Cultivate an environment that supports diversity and reflects high employee engagement and motivation

Typical KPIs and Targets

• Regular contact maintained with Regions / Compliance Analytics / Business / (Region and Global) to update / guide / challenge.
• Regular consultation is established with businesses and countries
• Participate in relevant global / regional forums focused risk management, as required.
• Guidance is appropriately documented, and best practices are shared, with thought leadership recognized.
• Provide input to regular committee reports within agreed timeframes.

Operational Effectiveness & Control [COMPLETE 3-4 AREAS]

• Promotes and takes accountability for the oversight, check and challenge, governance, risk assessment, support reporting and communication, that is directed towards setting up of a robust oversight framework.
• Review and constructively challenge the 1LoD performance, with a common objective to meet the aspiration of maintaining market leading monitoring protocols for the function.
• Captures key lessons learnt from regions, countries and Change Activities and ensure that these are taken onboard by the Global FC Risk Models function to drive the continuous improvement of the framework.
• Maintain awareness of operational risk within the assigned portfolio and minimize the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.
• Maintain and observe all HSBC control standards and implement and observe the Group Compliance Policy, including the timely implementation of recommendations made by internal/external auditors and external regulators.
• Critical SME risk steward oversight role on material risks and issues impacting the function.
• The role holder is expected to closely work with the Global Businesses, in assessing the risk landscape impacting the function and identifying improved controls that provide a balanced, risk-based approach to managing risks.

Typical KPIs and Targets

• Provided strategic steer and direction, aimed at improving the overall effectiveness of the FC Risk Modelling capabilities of the bank.
• Support the FC Risk Models framework that looks to identify opportunities and risk areas, within the function.
• Independent Model Review (IMR) & Audit / Assurance review findings are addressed promptly
• Strategies and policies to be developed and communicated clearly, in a timely manner
• Clear, risk-based advice/guidance given and decisions made.

Major Challenges (The challenges inherent in the role that require a continual test of the role holder’s abilities)

• To drive change in culture with respect to the management of AML Risk, in accordance with the three lines of Defense model.
• To manage the inter-linked and competing demands of developing, implementing and improving strategic Financial Crime compliance systems and controls on a Group wide basis, while also providing for adequate commercial view (efficiency of such a framework).

Role Context (The environment and operating conditions of the role including the extent of guidance and authority)

• The role holder must enable Group AML:
• To provide effective governance and oversight of and support to the FCCRM and FCC-RAM across LOBs globally
• To manage the inter-linked and competing demands of developing, implementing and improving the FCCRM and FCC-RAM on a Group-wide basis
• To respond to and anticipate the requirements of law and regulation across the Group’s diverse geographies and businesses
• The role often involves issues for which there is no clear cut solution but requires the ability to provide judgment and clear direction.  The nature of the role requires close working contact with senior stakeholders across 1LoD/2LoD business and functions.

Management of Risk (Operational Risk / FIM requirements)

• The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organisation.  This will be achieved by consistently displaying the behaviors that form part of the HSBC Values and culture and adhering to HSBC risk policies and procedures, including notification and escalation of any concerns and taking required action in relation to points raised by audit and/or external regulators.
• The jobholder is responsible for managing and mitigating operational risks in their day-to-day operations. In executing these responsibilities, the Group has adopted risk management and internal control structure referred to as the ‘Three Lines of Defense’.  The jobholder should ensure they understand their position within the Three Lines of Defense, and act accordingly in line with operational risk policy, escalating in a timely manner where they are unsure of actions required.
• Through the implementation the Global AML, Sanctions and ABC Policies, supporting Guidance, and Line of Business Procedures the jobholder will make informed decisions in accordance with the core principles of HSBC's Financial Crime Risk Appetite.
• The following statement is only for roles with core responsibilities in Operational Risk Management (Risk Owner, Control Owner, Risk Steward, BFCR, and Operational Risk Function)
• The jobholder has responsibility for overseeing and ensuring that Operational risks are managed in accordance with the Group Standards Manual, Risk FIM, & relevant guidelines & standards.  The jobholder should comply with the detailed expectations and responsibilities for their core role in operational risk management through ensuring all actions take account of operational risks, and through using the Operational Risk Management Framework appropriately to manage those risks.

This will be achieved by:

• Continuously reassessing risks associated with the role and inherent in the business, taking account of changing economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new technology.
• Ensuring all actions take account of the likelihood of operational risk occurring, addressing areas of concern in conjunction with Risk and relevant line colleagues, and also by ensuring that actions resulting from points raised by internal or external audits, and external regulators, are correctly implemented in a timely fashion.

Observation of Internal Controls (Compliance Policy / FIM requirements)

• The jobholder will adhere to, and be able to demonstrate adherence to, internal controls and will implement the Group compliance policy by adhering to all relevant processes/procedures
• The term ‘compliance’ embraces all relevant financial services laws, rules and codes with which the business has to comply. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators
• The following statement is only for roles with managerial or specific Compliance responsibilities
• The jobholder will implement measures to contain compliance risk across the business area. This will be achieved by liaising with Compliance department about business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimizing relations with regulators

Role Dimensions (e.g. balance sheet size, lending/expenditure limits, size/volume of transactions, budget. in USD’000)

• The job holder will be reporting to Head of FC Risk Stewardship CoE.
• The role holder’s responsibilities cover all the HSBC Bank’s operating jurisdictions

To be successful you will:

• Substantial experience in the financial services industry
• Good knowledge of Financial Crime and Anti-Money Laundering regulations and guidance.
• Understanding of Financial Action Task Force (FATF) process in addition to regulatory regimes of designating jurisdictions as High Risk Third Countries (HRTC)
• Experience and strong understanding of the Customer Due Diligence / Know Your Customer process
• Experience of dealing with regulatory matters and able to support in interactions with Regulators
• Understanding of factors that drive country specific risk ratings by reference to multiple data sources.
• Ability to determine country specific data sources that give a reliable/consistent output in relation to the risk a jurisdiction may pose.
• Experience in FC Analytics / IMR review process (Preferred)
• Lateral thinker with an ability to interpret and solve complex issues
• Excellent communication (written and verbal) and inter-personal skills with relation to stakeholder management
• An ability to develop practical, pragmatic, risk based and cost-effective solutions to complex issues which may have a global impact
• An ability to prioritize conflicting demands, meet tight deadlines and problem solve in a dynamic environment
• Proficient in analyzing and manipulating data, with an ability to present complex conclusions

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