Manager, Financial Crime CIB / WPB

The Compliance function is a Second line of defence (LOD) function, responsible for reviewing and challenging the activities of the Group’s businesses (also referred to as “the First LOD”) to ensure that they effectively manage as “Risk Owners” the risks inherent in or arising from the conduct of their activities and for which they are responsible. The Second LOD consists of 'Risk Stewards' who are independent of the commercial risk-taking activities undertaken by the First LOD. The Compliance function is a Risk Steward for a number of non-financial risks in accordance with HSBC Group’s risk framework.

Role Purpose:

• Primarily to support the Head of Financial Crime (FC) to maintain an effective FC control framework and discharge the Financial Crime Risk (FCR) responsibilities of Corporate and Institutional Business (CIB) and Asset Management busienss in Japan.
• Additional responsibilities include the provision of advice on FCR issues and liaison with senior line and local management in planning how FCR should be managed, operate and function in order to serve management and business needs.
• The role needs to liaise with and support the several country FCR functions and other key stakeholders including regulatory compliance, legal, risks, onboarding functions and other CIB and AM  work stream to ensure processes are coordinated and implementation risks and issues are considered and addressed.

• The primary accountability is implemented by the need to conduct compliance reviews in order to determine the effectiveness and performance of compliance activities across the region, which will involve FCR related monitoring, reporting and certification; fostering a compliance culture and optimizing relations with regulators.
• Support any ad-hoc and special projects, mainly related to FCR system changes and implementations, as directed by the Chief Risk and Compliance Officer (CRCO), working with Risk and Compliance (R&C). Opine on FC related process improvements on day to day operational tasks including the production of weekly and monthly MI.
• The articulation of HSBC Japan risk appetite and policies with respect to FCR, money laundering, sanctions, internal and external fraud, tax evasion, terrorist financing, bribery and corruption.
• Stay at the forefront of key regulatory changes in relation to FC to assist proactive communication with the counterparts in country & region and implementation of appropriate policy and framework to manage the changes.

Principal Accountabilities: key activities and decision making areas

The following principal accountabilities are aligned to the Compliance Services and Processes Model. Additional detail is available in the Model.

Impact on the Business

• Proactively identify financial crime risk within the client portfolio and potential impacts on HSBC
• Proactively identify financial crime risk change and potential impacts on Business Model in country
• Development and continuous review for appropriateness of control framework to monitor financial crime developments impacting on business in country
• Support the regional and local implementation plans to quantify impacts and implement actions to address, manage and mitigate impacts of regulatory changes on business
• Support the development and implementation as required FC policies and systems that ensure that Business’s exposure to financial crime and reputational risks is managed, in a practical and effective manner, including efficient and reasonable deployment of resources and an understanding of the business operations and needs.
• Resolve any/all identified issues promptly, and escalate concerns to Senior FC manager as appropriate to ensure timely awareness of any material concerns.

Customer / Stakeholders

• Assist Chief Risk & Compliance Officer (CRCO) in managing FC risk and enforcing various FC-related Act, rules and regulations of Japan working with Compliance colleagues.
• Support CRCO in the provision of reports on AML/Sanctions issues working with Compliance colleagues.
• Ensure Compliance Colleagues are appropriately advised of material FC issues.
• Liaise with relevant Regional stakeholders within business and other functional teams to provide business expertise on all FC matters from client issues to FC Strategy
• Demonstrated ability to communicate effectively across all levels.

Leadership and Teamwork

• Assist Chief Risk & Compliance Officer (CRCO) in managing FC risk and enforcing various FC-related Act, rules and regulations of Japan working with Compliance colleagues.
• To liaise with the Region FC team and other R&C teams covering businesses
• Build open and two way communication with Regional FC, functional and other business partners.

Operational Effectiveness and Control 

• Ability to support decisions with sound reasoning. Ability to clearly articulate business and regulatory implications of analysis and findings.
• To assist Country head of FC, to manage and deal with the day to day administration of the FC Japan matters.
• Support the alignment of business operating practices with changes in Global Financial Crime Standards and regulatory risk, and ensure that Financial Crime Framework remains appropriate.
• Resolve any/all identified issues promptly, and escalate concerns as appropriate to ensure timely awareness of any material concerns (per internal guidelines).
• Maintain and observe all HSBC control standards and implement and observe the Group Policy, including the timely implementation of recommendations made by internal/external auditors and external regulators.
• Maintain awareness of operational risk within assigned portfolio and minimise the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.

Management of Risk

Demonstrate leadership on R&C matters. Maintain awareness of operational risk and minimize the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting in accordance with Group Operations FIM. 

Leadership in relation to FC regulatory and compliance risk impacting or with the potential to impact the business across the country.

Observation of Internal Controls

Maintain and observe HSBC internal control standards, implement and observe Group FC Policy, including the timely implementation of recommendations made by internal/external auditors and external regulators.  Foster a compliance culture and implement Group FC Policy by managing compliance risk in liaison with the Regional FC team, Regional Compliance Officer or Local Compliance Officer, ensuring adequate compliance resources are in place and training is provided, and optimising relations with regulators.

Ensuring compliance with relevant compliance policies and FIM requirements as they relate to FC.

Local Job Requirements

Major Challenges

HSBC is an extremely diverse business with significant geographical spread and activities that span a universal banking model, including continuing to innovate to keep abreast of changes in financial services markets globally.  Such activity is in an increasingly regulated and complex global environment with often little consistency between laws and regulations in different jurisdictions and regulators taking a far more proactive approach in ensuring local compliance with their requirements and imposing increasingly stringent sanctions for breaches.  It is the role of the Financial Crime Manager, as a key senior member of the Japan Compliance function to assist HSBC Japan in achieving a balance between the demands of regulators, external bodies and governmental initiatives and the Group’s shareholders and customers in enacting financial crime; being alive to the political, management, regulatory and reputational implications of a particular decision and courses of action at a global level; assisting executive management in the development of controls and systems and influencing the way in which the business is conducted in order to manage these risks, meeting Group risk appetite.  The increased focus on individual liability for senior managers, particularly risk heads, makes it increasingly important for the Group to be able to evidence adequate systems and controls.  The role is one where regulatory authorities have high expectations and is likely to come under scrutiny as part of any major regulatory investigation.

Role Context

The role holder has senior accountability for implementing business-critical set of policies and operational activities in managing and leading on financial crime across HSBC Japan. This can involve dealing with major issues for which there is no clear cut solution whilst still being able to provide judgement and clear direction. Where items of major consequence are involved, engagement with the relevant top level management and governance bodies will be expected, directly and through collaboration with the Chief Compliance Officer.  The nature of the role requires close working contact with other senior executives across the HSBC Japan but particularly the R&C department. Appropriate presence in external stakeholder fora may also be necessary.

Certifications, Qualifications and Experience

• Preferred experience as a regulator, or a senior compliance manager within a global firm, in the financial services industry. 
• Detailed and extensive knowledge of the HSBC Group structure, its business and personnel, and HSBC’s corporate culture.
• Significant leadership experience and an experienced strategic thinker.
• Excellent verbal and written communication and inter-personal skills, with experience of dealing with executives at all levels in Japanese and in English
• Ability to develop practical, cost effective solutions to complex global issues.
• A legal or formal accountancy qualification or professional background in relevant risk or audit discipline.