Job Purpose:

To establish, implement and maintain a risk-based framework in order to perform Know Your Customer (KYC), Anti-Money Laundering and Terrorist Financing (AML/TF) compliance functions, which include efficient gathering and reviewing of new client information, as well as monitoring financial transactions for existing clients to identify suspicious activities. This includes the Sanctions screening obligations in line with Regulations in force.

This will be done by working closely and in conjunction with the Anti-Financial Crime Management team who provide direction for the department.

The incumbent may be required to work on an extended timetable till 18:00

Technical / Functional Responsibilities:

KYC

Develop and maintain a risk-assessment framework, which is in line with the Bank’s risk tolerance, for the classification of customer accounts.
Establish a KYC methodology which screens all individuals opening accounts with the Bank. This would include authorised signatories, directors, and ultimate beneficial owners for the Bank’s clients.
Develop and maintain a customer profiling process which allows for the building of a thorough understanding of the customer’s/relationship profile and behaviour, in line with the Bank’s customer acceptance policy.
Act as a subject matter expert to employees, providing guidance on what actions to take in dealing with high-risk accounts.
Develop and maintain good relationships with other regulatory bodies, with the aim of exchanging information in pursuance of the respective regulatory and supervisory functions.

AML/TF

Establish a customer risk-based methodology to review the activities undertaken through personal accounts currently being used by CBM clients, predominantly staff members.
Develop a risk-based methodology for prioritising the review of transactions which use the Central Bank of Malta corporate accounts as an intermediary or as the beneficiaries’ accounts.
Identify, investigate and report suspicious activity and transaction, ensuring detailed and prompt investigation of all AML/TF incidents and cases as necessary.Escalate any material risk relevant information to the Money Laundering Reporting Officer (MLRO) or the MLRO designate.
Raise the required Suspicious Transaction Report (STR) and assist the Bank’s MLRO and the competent authority (eg: FIAU) with the required information when transactions are confirmed as being suspicious following thorough investigation.
Collect, analyse and store documented proof associated with transactions which are beyond the risk threshold as defined for the screened process.
Maintain complete and updated records which are required to adequately monitor the Bank’s relationship with its customers, to understand the customer’s ongoing business and activities, and if necessary, to provide an audit trail in the event of disputes, legal action, inquiries and investigations that could lead to regulatory actions or criminal prosecution.
Establish a compliance methodology for corporate customers of the Bank, generally Government Departments, which take cash deposits from their clients and assist them with setting up of the necessary forms and reports which may have to be supplied to the Bank on as required for verification of source of funds.
Stay current with money laundering and terrorist financing behaviours, issues, policies, regulations, criminal typologies, industry best practices, and developing trends.
Work in close liaison with the Money Laundering Reporting Officer (MLRO) and the MLRO Designate at the Bank to ensure that any regulating authority decision related to AML/TF is implemented.
Timely and accurate reporting to the Authorities/ Regulators on any Refer for Information requests.
Support the MLRO and MLRO Designate in general compliance awareness and refresher training of staff members.

Sanctions

Establish the methodology for the screening of all incoming and outgoing payment instructions.
Ensure adequate tools are used to provide real time up-to-date sanction screening of payment messages.
Assess transactions flagged as suspicious by the sanctions monitoring systems and provide guidance to the operators, whether to process the ‘hit’ payments or otherwise.
Escalate and co-ordinate actions with the sanctions monitoring board when required.
Maintain hit reducing rules (whitelist) to increase efficiency by reducing the number of false positive alerts that operators need to manage.
Provide correspondent banks with the necessary assistance and information related to the Bank’s payment/s that failed their screening tests.

Projects

Assist the MLRO Designate with managing of projects relating to the adoption of compliance software applications and the migration of data thereto, in order to ensure a smooth transition and also that the specifications of the software is in line with expectations and is fit for purpose.
In line with the above, ensure that the department staff have the required training and procedures are set-up to ensure a full understanding of the compliance software applications being utilised.

Others

Make recommendations on the validity, or otherwise, of tools to monitor, analyse, and report suspicious activity and help in identifying potential weaknesses in processes ensure proper record-keeping of data collected and analysed.
Participate in committees, working groups and task forces (local or ESCB).
Produce management information when required.
Develop and maintain Working Instructions and Policies and Procedures documentation relevant to the post.
Ensure that policies and procedures are followed and to report any non-compliance.
Assist with the maintaining of Business Continuity Plans to address processes which have a high business impact.
Report on activities undertaken.
Ensure a high quality / standard of work and service throughout.
Support a culture that encourages teamwork, quality and timeliness in achieving goals.
Perform any other duties which may be assigned from time to time.

Competencies and Proficiency Levels

Within the context of their specific tasks, the incumbent is expected:

To be truthful and honest;
To have a positive, can-do attitude;
To share the Bank’s intolerance of sexism, homophobia, xenophobia and racism, and to be respectful and caring towards others irrespective of sexual, religious and political orientation;
To carry out their tasks professionally and ethically;
To communicate effectively;
To have a sense of the value of time and priorities;
To respect security and confidentiality; and
To be able to lead and to work in teams as may be the case.

Experience and Qualifications

A degree at MQF Level 6 in Banking and Finance or a closely related discipline together with two years of professional experience.

Consideration will be given to candidates who hold an MQF Level 4 or 5 qualification preferably in the area of Banking and Finance or a closely related discipline together with at least eight years relevant work experience in compliance and demonstrate proven ability to perform the tasks pertaining to the position.

ACAMS/ ICA certification would be considered as an asset.
Good knowledge of the fundamental AML/TF and sanctions legislation is essential.
Strong knowledge of retail banking operations, accounting and current financial market practices.
Very good analytical skills, with the ability to organise and analyse complex data sets.
Computer literacy and proficiency in the use of Microsoft Office Suite (Excel, Word, PowerPoint and Access) and Business Intelligence is essential.
Ability to use pivot tables and work with an advanced statistical database and statistical methods and functions.
Familiarity with AML issues and suspicious transaction monitoring systems would be considered as an asset.
Experience KYC automated solutions.
Must have project management skills.
Strong written, communication and presentation skills.
Knowledge in written and spoken Maltese would be considered an asset.
Must be proactive in problem solving and must have a high level of attention to detail.
Preferably some legal or regulatory experience.
A disposition to work on an extended timetable till 18:00.

Working Relationships and Lines of Communication

Internal

Technology Services for specialist support.
Legal Department.
Internal Audit Department.
Payments & Banking Operations Department.
Operational Risk Management Office.
Other offices, with respect to KYC requirements.

External

Correspondent Banks, Government Departments, and other public entities holding an account with the Bank.
MTEUROPAY System Participants.
Financial Investigative Analysis Unit
Malta Financial Services Authority
Software suppliers

Senior Anti-Financial Crime Officer

Job Description