VP Financial Crime Control

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Business Descriptor:

VP – Financial Crime Control (FCC) | GCB 5 | IWPB | HIBU – GIFT City

Location: GIFT City, Gandhinagar, Gujarat

Job purpose

Support IWPB in HIBU GIFT City (covering Wealth, Transaction Banking and Lending) by providing second line of defence FCC oversight, challenge and advisory. The role helps ensure the business operates in line with the HSBC Global Financial Crime Risk Management (FCRM) Framework, applicable Group Standards, and local regulatory requirements (including IFSCA expectations, as applicable), while enabling sustainable growth and protecting customers and the bank.

Principal responsibilities

Financial crime governance and oversight (2LoD)

• Provide FCC oversight and credible challenges to IWPB activities, ensuring financial crime risks are identified, assessed, mitigated and reported.
• Support local FCC governance (committees/forums), including agenda inputs, papers, minutes/actions, and timely escalation of material risks, breaches and emerging issues.
• Promote a strong risk culture and consistent application of HSBC risk appetite and customer acceptance standards.
• Work closely with FC Risk Steward in proactive identification of issues and take steps to address them.
• Carry out read across on the audit findings in other markets

Customer risk management (CDD/EDD) – onboarding and lifecycle

• Provide guidance and challenge on customer risk rating, due diligence approach, and EDD triggers for higher-risk customers (e.g., complex ownership, PEPs, high-risk jurisdictions, intermediaries).
• Guide business in reviewing and revising the Operating procedures of onboarding and periodic review.
• Review and opine on higher-risk relationships and exceptions in line with delegated authorities and escalation pathways.
• Drive quality and consistency across onboarding, periodic reviews and event-driven reviews, ensuring clear rationale and robust audit trails.

Product and proposition advisory (Wealth, Transaction Banking, Lending)

• Act as FCC advisory for IWPB products and services, ensuring controls are embedded “by design” across:
  Wealth: investment flows, portfolio funding/withdrawals, third-party payments, complex structures
  Transaction banking: payments, trade-related flows where applicable, channel risk
  Lending: purpose of borrowing, source of repayment, collateral-related risks, misuse typologies
• Support new product approvals, change initiatives, and process re-engineering by assessing inherent risk, control design and residual risk; document FCC requirements and sign-offs as required.

Sanctions and screening risk management

• Provide oversight and challenge of customer and payment screening controls, including escalation of potential matches, control weaknesses and data quality issues.
• Support sanctions risk assessments and ensure alignment with HSBC Group Standards and applicable legal/regulatory requirements.

Transaction monitoring, investigations and suspicious activity governance

• Oversee and challenge the effectiveness of transaction monitoring coverage for IWPB activity (wealth flows, payments, lending-related movements), including typology alignment and scenario coverage.
• Review themes from investigations/case outcomes to identify control gaps, training needs and opportunities for tuning/optimisation.
• Support governance around suspicious activity escalation and regulatory reporting processes (e.g., STR/SAR decisioning), in line with local requirements and HSBC standards.
• Be single point of contact for FC related matters

Risk assessment, control testing and issue remediation

• Support periodic financial crime risk assessments for IWPB (customer segments, products, channels and geographies).
• Challenge the design and operating effectiveness of key FC controls through thematic reviews/quality assurance activity (as applicable).
• Drive remediation of issues to closure, ensuring actions are timely, evidenced and sustainable; validate fixes and track residual risk.

MI, reporting and insights

• Produce/review FC MI for IWPB leadership and governance forums (KRIs, breaches, backlogs, EDD volumes, screening/TM performance, thematic findings).
• Ensure the Key Control Indicators are managed well within thte risk appetite of the Bank
• Provide forward-looking insights on emerging risks and typologies relevant to IWPB and cross-border activity in GIFT City.

Stakeholder management, audit and regulatory support

• Build strong partnerships with IWPB, Operations, Client Onboarding/KYC, Compliance, Risk, Legal, Technology and Group/Regional FCC.
• Support responses to internal/external audits and regulatory examinations; ensure timely, accurate and well-evidenced submissions.
• Contribute to training and awareness for front office and operations teams (red flags, escalation routes, “how we do things” under HSBC standards).

Key stakeholders

• IWPB Business Heads, Relationship Management, Product (Wealth / Transaction Banking / Lending)
• Client Onboarding/KYC, Operations, Investigations/Case Management teams
• Country/Regional FCC and Group FCC
• Risk (including Operational Risk), Legal, Compliance Advisory
• Technology/Change, Data & Analytics
• Internal Audit and regulators (via appropriate governance)

Role context and decision-making

• Operates as a second line of defense FC role providing oversight, challenge and advisory.
• Makes recommendations and escalations in line with delegated authorities; supports risk-based decisioning on higher-risk customers, product changes and control remediation.
• Expected to exercise sound judgement, document decisions clearly, and escalate early where risk is outside appetite or controls are ineffective.

Knowledge, experience and qualifications

Essential

• Strong experience in FCC/AML within banking/financial services, with coverage across Wealth and/or Transaction Banking and/or Lending (combined coverage preferred).
• Working knowledge of AML/CTF, sanctions, CDD/EDD, screening, transaction monitoring, investigations and governance.
• Proven ability to influence stakeholders, provide effective challenge, and drive issues to closure.
• Strong analytical skills and clear written communication (committee papers, risk assessments, MI commentary).

Desirable

• Experience in IWPB/wealth propositions and cross-border client risk.
• Familiarity with GIFT City / IFSCA environment and operating model considerations.
• Professional qualifications such as ICA/ACAMS (or equivalent).

Risk and control responsibilities

• Demonstrates strong risk awareness and supports effective management of FCC risks in line with the HSBC FCRM Framework, Group Standards and local regulatory requirements.
• Ensures timely escalation of material risks/issues and maintains robust documentation and audit trails.
• Supports a speak-up culture and continuous improvement mindset.

HSBC Values

We Value Difference | We Succeed Together | We Take Responsibility | We Get It Done