Subdirector de Analisis de Comportamientos de Clientes

Role Purpose

To collect, consolidate and assure the quality of all required client information to enable efficient decision-making and effective execution of decisions related to customer exits, in line with HSBC Global Standards and local governance requirements.

Principal Accountabilities:  Key activities and decision-making areas

Impact on the Business

• This role will lead a team of 12 and will be directly responsible for the management of circa 50,000 customer exits per annum - incorporating Compliance, Customer Experience and Operational considerations.
• This is a position that will lead the IWPB Secretariat team and manage/direct the related EXCO meetings on the decisions that need to be made.
• The Senior Client Selection Secretariat Manager oversights and supports the CSEM WPB team.
• The Senior Client Selection Secretariat Manager manages a team of in Country Secretariat Case Analysts who will be responsible for obtaining all required customer information as part of the Build the Case stage of the exit process, they will coordinate with other stakeholder (including RM, Compliance, Product/ System Owners) to ensure a complete relationship view on the customer is provided. They will be responsible for ensuring appropriate and adequate information is gathered for submission to In Country CS Committee.
• The Senior Client Selection Secretariat Manager is responsible for coordinating the Reputational Risk and Client Selection Committee and ensuring decisions and minutes are documented.

Customers / Stakeholders

• Analysis of MI relating to the implementation of CSEM, using the data to inform the business on current performance and impacts, and then working with the Business to identify trends and actions required.
• Work with Business areas to raise the profile of Global Standards, ensuring a 'fear' culture is not created because of increased regulation and focus on being compliant.
• The role is pivotal to supporting the implementation of the key strategic objective of Global Standards.  Therefore, the role holder is required to have access to and influence at all levels across the Business e.g., Business Risk, Compliance and Front-Line teams.
• Work closely with Customer Experience and High-Risk Approvals to ensure they are informed and fully support and contribute to the implementation of CSEM

Leadership & Teamwork

•      Pivotal member of the cross functional team to be ambassadors of Policies and Procedures of CSEM Process, identifying and ensuring implementation of specific programs and plans.
•      Identify and engage with key stakeholders to gain support and ensure that strategies and solutions will be effectively delivered.
•       Act as a subject matter expert, working with senior stakeholders and business areas to influence and shape the thinking around Policies and Procedures of CSEM Process.
•      Share best practice globally.
•      Drive employee engagement at the same time as achieving complex business objectives.

Operational Effectiveness & Control

•      Protect HSBC’s reputation and ensure there is no detriment to the relationships of our target customers.
•      Be a key driver in the implementation of Policies and Procedures of CSEM Process.
•      Manage and escalate risks and issues relevant to activities allocated as appropriate.

Major Challenges

Leading a team that undertakes the following actions:

• • The WPB Country Head of CSEM is responsible for the end-to-end oversight of operational effectiveness of CSEM process and procedures for IWPB in their country.
  • Endorses Regional/Country WPB CSEM Procedures for Global WPB Head approval and ensures policies, procedures and R&R are locally fit for purpose, published and available to all CSEM staff, with their respective variance logs published on relevant intranet/portals for approval by Global WPB Head
  • Oversees the WPB CSC secretariat responsibilities in their country
  • Acts as WPB FLoD execution contact for all IWPB CSEM risk appetite and financial crime risk matters
  • Manage relationships with related CSEM stakeholders with a clear understanding that operational effectiveness requires consistent Cross Line of Business and Cross Border execution.
  • Oversees CSEM Quality Control and Quality Assurance results along with associated remediation
  • Oversees BRCM, M&T, FCC Assurance, internal/external audit results along with associated remediation
  • Oversees CSEM Governance through related forums and ToRs in line with approved guidance. Where processes sit within Functions (FCC/AMLi/Sanctions) or HOST, these should be managed through subsets PLAs and SLAs between COO offices and such parties with performance tracked through Management Information and RAS management to ensure aspects outside risk appetite are moving towards tolerance levels and escalating accordingly to COOs / IWPB Heads accordingly.
  • Ensures all sites are able to execute the CSEM process in an operationally effective manner using an automated tool that generates consistent and quality MI, enables efficient resources allocation against a CSEM blueprint, and supports cross-border and cross-business line decisioning and execution. Ensures a local resourcing model is maintained by all relevant CSEM parties (eg HOST/FCC/Sanctions /AML)
  • Ensures CSEM staff are sufficiently trained and capable of effectively delivering CSEM
  • Collaborates with SLoD and HOST to ensure all customers considered to potentially exceed HSBC's financial crime risk appetite are identified and subject to further evaluation through a robust objective process. Oversees:
    • Quality and completeness of triggers and related closure
    • Feedback to ensure risk management is fit for purpose
  • Ensures exit decisions are informed by good quality and pertinent information and exit execution can be carried out comprehensively across the Group.  This ultimately enables effective financial crime risk management while ensuring compliance with conduct- and legal-related obligations about treating customers fairly.  Ensures adherence to SLAs or Risk Mitigation as appropriate for constraints.
  • Ensures objective and informed decisions are taken by suitably qualified managers in accordance with HSBC's financial crime risk appetite as to whether a customer should be retained or exited, and whether any additional risk management (such as monitoring or restrictions on activity) is appropriate.
  • Ensures customers outside HSBC's financial crime risk appetite are exited across the Group and pose no further financial crime risk to HSBC.
  • Ensures customers previously exited for financial crime reasons cannot re-onboard by ensuring that stakeholders have updated relevant screening mechanisms (GEL), with “GEL “true hits” triggered into CSEM in such a way as to ensure such cases are exited with appropriate FCR governance.
  • Oversees management of resources to support initiatives/ change programmed coordinated by Group

Role Context

• Reports to Head of Client Risk Management and Support IWPB
• Ability to execute role with a level of autonomy while being mindful of when to seek guidance and approval

Management of Risk

The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organisation.

The jobholder will also continually reassess the operational 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.

This will be achieved by ensuring all actions take account of the likelihood of operational risk occurring.

Also by addressing any areas of concern in conjunction with entity management and/or the appropriate department.

Observation of Internal Controls

The jobholder will also adhere to and be able to demonstrate adherence to internal controls. 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 jobholder will implement the Group compliance policy by containing compliance risk in liaison with Global Head of Compliance, Global Compliance Officer, Area Compliance Officer or Local Compliance Officer. The term ‘compliance’ embraces all relevant financial services laws, rules and codes with which the business has to comply.

This will be achieved by adhering to all relevant processes/procedures and by liaising with Compliance department about new 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 optimising relations with regulators.

HSBC is an equal opportunity employer committed to building a culture where all employees are valued, respected and opinions count. We take pride in providing a workplace that fosters continuous professional development, flexible working and, opportunities to grow within an inclusive and diverse environment. We encourage applications from all suitably qualified persons irrespective of, but not limited to, their gender or genetic information, sexual orientation, ethnicity, religion, social status, medical care leave requirements, political affiliation, people with disabilities, color, national origin, veteran status, etc., We consider all applications based on merit and suitability to the role.