Organise and supervise the activities and work of subordinates (AML Governance team) to ensure that all work within a specific area of the activity is carried out in an efficient manner which is consistent with operating procedures and policy.
Develop, maintain and update the Bank?s operating procedures in the area of AML/CFT and direct the implementation of related processes and controls, so that all AML/CFT activities are conducted in compliance with the approved procedures.
Provide strong oversight of the AML/CFT transaction monitoring process (by the AML Governance team) to ensure that all detected unusual and/or suspicious activities are being investigated and reported in line with applicable AML regulations in order to protect the interests of the Bank from regulatory criticism, financial penalties and reputational damage.
Provide constructive feedback to subordinates on the improvement of the quality of suspicious transactions reports (STRs) filed with the QFIU.
Provide oversight on the progress of OCDD and event driven reviews of CDD conducted by business including the review of account activities of High Risk customers.
Review all cases to be presented to Exit Committee (primarily due to STRs filed on a customer or a customer was carrying out business activities in his/her person account or customer was involved in unauthorized trade of crypto-assets or crypto-currency) and provide constructive feedback re materiality of risk should such customers are not exited from the Bank.
To inform QCB for Commercial Bank?s Decision to Terminate a Business Relationship with Customers.
Provide an effective oversight on the end to end process of approving a high risk customers such as PEP, Cash Intensive businesses, non-resident customers etc.
