Support the MLRO and overall manager of the Ireland Financial Crime team in the execution and enhancement of the policies, procedures, systems and controls designed to counter the risk that the company might be used to further financial crime. The role holder will help lead financial crime compliance initiatives within the Ireland and broader EMEA framework, support the identification and analysis of key AML regulatory developments, and provide subject matter expertise, oversight support and credible challenge to relevant stakeholders across lines of business and legal entities in scope.
The role includes supporting the manager in delivering effective AML/CFT oversight, driving consistency in standards, assisting with the governance and management information framework, and helping coordinate responses to regulatory, business and control matters. The role holder will also support engagement with European MLROs and stakeholders, contribute to high standards in policies, procedures, systems and controls, and act as a trusted advisor on financial crime matters within their area of responsibility.
The role holder is also expected to demonstrate strong proficiency in the use of technology, data and AI-enabled capabilities to improve the effectiveness, efficiency and insightfulness of financial crime compliance activities. This includes using data-driven tools and automation responsibly, identifying opportunities to enhance surveillance, reporting, quality assurance and workflow management, and applying sound judgment and governance when using AI in support of business and control objectives.
Regulatory Responsibilities and Duties
- Support the MLRO / Head of AML/CFT Compliance in maintaining an effective, proportionate AML/CFT framework aligned to the firm’s money laundering and terrorist financing risk profile.
- Assist in the development, implementation and maintenance of AML/CFT policies, procedures, systems and controls.
- Support the preparation, maintenance and periodic review of firm-wide and business risk assessments for ML/TF risk.
- Contribute to ensuring the AML/CFT control framework is appropriately designed, documented, implemented and subject to ongoing review.
- Prepare and deliver high-quality analysis, reporting and recommendations to support advice provided to the Board, senior management and relevant committees on AML/CFT obligations, emerging risks, regulatory expectations and control weaknesses.
- Support ongoing monitoring of compliance with applicable AML/CFT legal and regulatory requirements.
- Assist in assessing whether appropriate customer due diligence, enhanced due diligence and ongoing monitoring arrangements are in place and operating effectively.
- Support the processes for identifying, investigating and escalating unusual or suspicious activity, including the preparation of materials to support suspicious transaction reporting where required.
- Track AML/CFT breaches, control gaps and remediation actions, and support appropriate escalation and closure.
- Assist in the development and maintenance of AML/CFT management information and reporting for senior management and the Board.
- Help promote a strong AML/CFT culture across the organisation and support delivery of relevant, risk-based AML/CFT training and awareness.
- Support engagement with the Central Bank of Ireland and other competent authorities on AML/CFT matters, including regulatory reviews, inspections and information requests, as directed by the MLRO / Head of AML/CFT Compliance.
- Support periodic independent review and testing of the AML/CFT framework and track remediation of findings.
- Maintain awareness of legal, regulatory and typology developments and help ensure the firm’s framework is updated accordingly.
Use technology, data analytics and AI-enabled tools appropriately and responsibly to enhance monitoring, reporting, documentation quality, workflow efficiency and risk insight, in line with applicable governance, policy and control requirements.
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BNYM General Responsibilities and Duties
Support the MLRO and broader EMEA Financial Crimes Compliance leadership team in implementing and operating the EMEA financial crimes oversight framework.
Provide support in relation to sanctions compliance oversight, transaction monitoring oversight and financial crimes compliance testing activities.
Support the periodic financial crime risk assessment process for prescribed jurisdictions and help coordinate contributions from relevant stakeholders.
Assist in keeping the business apprised of changing regulatory requirements and expectations, and support implementation planning for new requirements.
Provide advisory support to legal entities, lines of business, platforms and operational areas on financial crime matters within delegated scope.
Support the receipt, review and investigation of internal incident reports and assist with case analysis, documentation and escalation to enable determination of whether an external suspicious activity report should be made to the relevant FIU.
Prepare materials, updates and reporting to support escalation of issues to senior management, committees and the annual MLRO reporting process, and help follow up on agreed actions.
Work with internal training teams on the development and enhancement of induction and periodic awareness training in relation to financial crime for the prescribed jurisdiction.
Support global and regional senior leadership initiatives intended to strengthen the financial crimes compliance programme throughout the company.
Attend relevant governance committees and working groups as a delegate, contributor or subject matter expert, as appropriate.
Work collaboratively with fraud colleagues in first and second line teams, as appropriate, recognizing that fraud is managed as an operational risk outside the formal financial crimes compliance framework.
Identify opportunities to simplify, automate or strengthen control activities through appropriate use of technology, including AI-enabled tools, while maintaining strong documentation, oversight, data handling discipline and compliance with internal governance standards.
Governance Responsibilities
Contribute to the effective governance of the Ireland and EMEA financial crime compliance framework.
Play an active role in committees, forums and local governance processes, offering constructive challenge, clear analysis and practical support to help the relevant committee or Board fulfil its responsibilities.
Build and maintain a strong understanding of the EMEA governance framework, including escalation requirements, and support clear, appropriate and evidenced apportionment of responsibilities across relevant stakeholders.
Ensure issues, decisions, actions and risk themes are clearly documented, tracked and escalated where appropriate.
Support the manager in using management information, data analysis and technology-enabled insight to improve governance reporting, issue tracking and decision-making.
Comply with all BNY Corporate Policies and Procedures including the Code of Conduct, HR policies and procedures, applicable to BNY.
Notify management and/or the Chief Compliance and Ethics Officer and Chief Risk and Compliance Officer, International on discovery of any material regulatory breach, in accordance with escalation requirements.
