Job Summary

To facilitate business and assist management by ensuring that the bank operate in accordance with (a) all regulatory and legal requirements and (b) all Group standards of conduct, so as to protect and enhance the reputation of the bank with their regulator and avoid significant financial loss.

Assists the bank and management in understanding and addressing all applicable laws and regulations. Directs the activities of the Compliance staff and acts as the liaison with regulatory agencies, internal and external advisors, and other internal control groups on compliance related issues. Works closely with management to establish an appropriate compliance culture throughout the bank including the development of specialized training programs

Perform regular and comprehensive compliance reviews and internal control oversight. To report regularly on compliance matters as per the Group Compliance reporting system. To report all identified breaches and corrective action taken on internal control matters. To ensure that the Compliance and Internal Control Officers comply with all Incident reporting Requirements. Be a local champion of the Banks Anti Money Laundering (AML) and combating the Financing of Terrorism (CFT) initiatives

Main Responsibilities

1. Shareholder &Financial:

    

-       To prepare and implement the annual compliance and internal control review plan and submit it for Group Compliance approval.

-          Implements KPI’s and best practices for role

-          Promote cost consciousness and efficiency and enhance productivity, to minimise cost, avoid waste, and optimise benefits for the bank.

-           Act within the limits of the powers delegated to the incumbent and delegate authority to the respective staff and monitor exercise of the same.

-          Demonstrate clear understanding of the important factors behind the bank's financial & non-financial performance.

-          To implement specific steps within the compliance program to ensure effective implementation of regulations and statutory requirements concerning Anti Money Laundering (AML) and Combating Terrorism Finance (CTF), QNB standards and Regulatory requirements.

-          Implement a checklist of regular internal controls including regulatory requirements, proper segregation of duties, proper reconciliation, proper custody of records and documents and transactions processing (system of permanent control of major risks).

B. Customer (Internal & External):

-          Maintain activities in accordance with Service Level Agreements (SLAs) with internal departments/units to achieve improvements in turn-around time.

-          Build and maintain strong/effective relationships with related departments/units to achieve the Group’s objectives.

-          Provide timely/accurate data to external/internal Auditors, Compliance, Financial Control and Risk when required.

C. Internal (Processes, Products, Regulatory):

1. Continuous Improvement:

-          Set examples by leading improvement initiatives through cross-functional teams ensuring successes.

-          Identify and encourage staff to adopt practices better than the industry standard.

-          Continuously encourage and recognise the importance of thinking out-of-the-box within the team.

-          Encourage, solicit and reward innovative ideas even in day-to-day issues.

2. Assessment Criteria:

• To implement specific steps within the compliance program to ensure effective implementation of regulations and statutory requirements concerning Anti Money Laundering (AML) and Combating the Financing of Terrorism (CFT) and Regulatory requirements.

• Implement a checklist of regular internal controls including regulatory requirements, proper segregation of duties, proper reconciliation, proper custody of records and documents and transactions processing (system of permanent control of major risks).

• Maintain a robust Compliance Monitoring Program as per Group Compliance standards covering all the required elements (Regulatory Inventory Matrix, Risk Control Matrix, Control Testing, and Risk Based Approach).

• Review and update applicable new/changes in regulations into the Compliance Monitoring Program.

• Ensure that all regulatory requirements being reflected into the Internal Control Repository and Annual Plan for testing purposes.

• Notify Business and Group Compliance of any major gaps or risks identified from the conducted assessment.

• Ensure review and update the Compliance Policies and Procedures where and when applicable on timely manner and as per the Group Standards. 

3.  Monitoring:

• Monitor action taken on Regulator/Central Banks inspectors’ recommendations to ensure effective implementation.

• Monitor adherence of business and support management to Central Bank/ Legal Authority regulations and statutory requirements.

• Oversee the standard of accounting and financial information, in particular the conditions under which such information is registered, retained and disclosed.

• Oversee global risk management by setting and ensuring the cohesion and efficiency of on-going control procedures throughout the entire branch.

• Verify compliance with all types of decision-making procedures and risk procedures as well as QNB standards.

• Monitor staff accounts specifically for the purpose of anti- AML/CFT.

4. Compliance and Internal Control Review:

• Conduct on-going compliance reviews as per the approved annual compliance review plan.

• Comply with Group Compliance reporting system.

• Ensure that the branch complies with all the Compliance & AML/CFT related regulations.

• Implement all changes in regulations at the Branch, and communicate them to Group Compliance including maintenance of appropriate registers to record receipt of new regulations and their subsequent implementation.

• Promote the employees’ awareness by providing Compliance/ AML/CFT training courses to the Branch (es) staff

• Review system changes and or enhancements of Regulatoryreturns to ensure that the Branch is in compliance with Regulatorypolicies.

• Provide advice service to the Branch Management in relation to product services (policies and procedures) from Compliance & Internal Control perspective.

• RSA, CSAs and KPCIs reviews unit responses on a rolling basis with spot checks and verify veracity and completeness of reporting.

• Ensure implementation of Group Compliance/ Group Internal Audit / banking commission / external auditors’ recommendations.

• Carry out the mandatory verifications and reviews required by Regulators/ Legal Authorities.

• Ensure policies and procedures are regularly reviewed, updated with any new regulations and implemented, including Compliance manuals.

• Review all critical reconciliations performed by Finance department and operations e.g. Suspense accounts and Sundry Accounts. Follow-up all outstanding entries/ differences.

5. Reports:

• Submit (Regular and Irregular) reports to Group Compliance detailing cases of non-compliance to Regulator/Central Banks’ regulations and statutory requirements.

• Prepare and submit the monthly compliance reporting to Group Compliance.

• Share the Compliance and Internal Control Committee MOMs with Group Compliance after each meeting.

• Prepare and retain monthly internal control reports for Group Compliance and the Country General Manager.

• Prepare annual report on internal control in coordination with Senior Management and Group Compliance.

• Prepare internal control report for every assignment conducted detailing the review objectives, scope and outcome.

• Make compliance and internal control record file of all of the branch’s activities and determine the frequency of each control procedure (daily, monthly, etc.) based on the risk involved and the efficiency of current procedures.

6. Local Central Bank / Legal Authorities:

• Liaise with local Central bank/regulator whenever required, response on queries and communicate issues raised by them and follow up such issues until final resolution.

• Coordinate between Regulator inspectors and Branch’s units/ departments to facilitate their mission.

• Carry out the mandatory verifications and reviews required by Central Bank/ Legal Authority.

• Liaise with local Regulator/Central bank whenever required response on queries.

• Monitor the Compliance status of the branch Regulatory Limits and Ratios.

• Monitor and ensure that all the Regulatory Reporting were submitted properly and on timely manner

• Follow-up on Central Bank/Legal regulator Circulars, Reports and Correspondence, where applicable.

• Carry out the mandatory verifications and reviews required by Central Bank/Legal authority to detect suspicious activities.

7. Anti-Money Laundering and Combating the Financing of Terrorism

• Developing and maintaining QNB AML/CTF policy in line with evolving statutory and regulatory obligations.

• Supporting and co-ordinating management focus on the money laundering risk in individual business areas.

• In consultation with management, determining and updating the money laundering risk-based approach and the risk assessment of the Bank’s customers, products and services.

• Ensuring that the Bank’s risk management policies, risk assessment profile and their application are adequately documented.

• Assisting management to develop and maintain an effective anti-money laundering and counter-terrorist financing compliance culture.

• Establishing and maintaining appropriate risk-based monitoring processes that are proportionate to the scale, nature and complexity of the Bank’s operations.

• Developing internal procedures in line with the requirements of the local Financial Regulator and legislation, Qatar Central Bank regulations, QNB Head Office policies and procedures, and international standards (such as FATF).

• Ensuring that all internal suspicion reports received are investigated effectively and without delay and determining whether such suspicions have substance and require disclosure to the FIU.

• Ensuring that all employees are aware of their personal obligations and the Bank’s procedures, and that all relevant employees are adequately trained in money laundering prevention.

• Ensuring that employees are complying with the stated policy and therefore monitoring operations and development of the policy to this end.

• Ensuring that all relevant employees are adequately trained in money laundering and terrorist finance prevention that the standards and scope of the training is appropriate, and that appropriate training records are kept.

• Making any recommendations for action to remedy any deficiencies in policies, procedures, systems or controls and following up on those recommendations.

• Representing QNB to all external agencies in the Country, and in any other third party enquiries in relation to money laundering prevention, investigation or compliance.

• Preparing an annual money laundering report for senior management.

• Undertaking independent monthly reviews of activity relating to selected (by the MLRO) high-risk accounts which are deemed to require additional monitoring over and above the standard reviews by the business. The results of the MLRO’s reviews are to be documented.

• Awareness of any relevant sanctions, prohibition or advisory notices applicable to the bank and its business.  Also as necessary advising management and relevant employees of the names of any individuals and institutions on the sanctions list.

• Promptly responding to any request from a regulator and/or law enforcement agencies for information to which they are legally entitled.

8. Financial Crime framework

-       Maintain a robust Financial Crime Framework as per QNB Standard by ensuring the following: 

-       Clearing transactions related to sanctioned / high-risk countries.  

-       Communications with correspondent / beneficiary banks (through Group Compliance) about Compliance Sanctions questionnaires, inquiries and confirmations.

-        Provide sanctions advisory services across the business units at the branch (Account openings, review agreements, etc.)

-       Released transfers (initially held by the correspondents) based on compliance interference

-       Provide Face-to-Face training sessions (i.e. Regulatory Compliance, AML/CTF, KYC, Sanctions, Tax Compliance, and Internal Fraud) as per the annual training plan, and ensure to cover 100% of the branch.  

-       Dedicated Specialized Training for the front line (First line of defence) related KYC, CDD, and EDD.

-       Governance on escalation matrix for handling Suspicious Transaction Reporting.

-       Review the appropriateness of the SAS scenarios with respect to the branch business profile

-       Review the quality of the alerts (redundancy, relevance, frequency)

-       Establish a branch AML/CFT comprehensive risk assessment

-       Review the STR mechanism including clear decision tree mechanism

-       Review the EDD measures for completeness

-       Review PEP categorization and related treatments

-       Update the CRA in line with HO new methodology

-       Ensure proper maintaining of Compliance IT infrastructure (i.e. KYC, Screening, and Profiling) platforms.

9. Fraud Control & ABC

-       Ensure ongoing Monitoring of Fraud Control Activities

-       Build a robust Fraud Control Framework as per Group Compliance Standards.

-       Build a robust ABC (Anti Bribery & Corruption) Framework as per Group Compliance Standards.

-       Ensure all Fraud Investigations are conducted promptly and referred to Group Compliance, where required

-       Follow up and closing for recommendations of Group Compliance Assurance / Investigation reports.

-       Ensure timely Fraud Reporting to Group Compliance and Regulator. 

-       Ensure guidance on Assessment / Gap Analysis of local requirements against QNB Policies & Procedures are followed and local fraud policies update accordingly

-       Ensure guidance are followed on Risk Control Self-Assessment, handling the fraud, tips and recommendations

10. Data Protection

-       Ensure all Policies and Procedures regarding Data Protection (where applicable) are in place and reviewed annually including ( DP Policy, Data Breach Incident, Data subject Rights, Privacy Statements)

-       Ensure appropriate Governance of Data Protection including Technical and Security measures

• Perform the tasks of the Local DPO (where applicable) including documenting training employees, monitoring privacy

-       Ensure an appropriate Data Protection Framework and internal controls are in place to monitor and ensure the branch adheres to relevant data protection laws.

-       Ensure detailed DPIA and ROPA is in place and up to date

-       Point of contact for the related regulator communication

-       Ensure appropriate training & awareness to all employees and staff regarding data protection

-       Ensure all DP breaches, incidents and Data Subject requests captured and reported to all relevant stakeholders in a timely manner.

11. Special Assignments & Investigations:

• Participate in special assignments & investigations as and when required

• Manage Customer Complaints and liaise with departments to ensure timely resolution as per local processes and regulatory requirements.

12. Advisory:

• Recommend improvement in branch’s policies and procedures as appropriate to be in line with new and or amended Legal Authority/Central Banks’ regulations and statutory requirements.

• Make necessary recommendations in order to improve the monitoring and efficiency of transactions.

• All other ad hoc duties and/or activities related to QNB that management may request of the employee from time to time

Learning & Knowledge:

-          Proactively identify areas for professional development of self and undertake development activities.

-          Seek out opportunities to remain current with all developments in professional field.

-          Hold meetings with staff and assess their performance and your teams overall performance on a regular basis.

-          Take decisive action to ensure speedy resolution of unresolved grievances or conflicts within the team members.

-          Identify development opportunities and activities for staff and facilitate/coach them to improve their effectives and prepare them to assume greater responsibilities.

Legal, Regulatory, and Risk Framework Responsibilities:

-          Comply with all applicable legal, regulatory and internal compliance requirements including, but not limited to, Group Compliance Policies and Procedures (AML & CTF, Anti-Bribery and Corruption, Sanctions Policy, Data Protection Policy, Fraud Control Policy, Whistle Blowing Policy, Conflict of Interest and Insider Dealing Policy).

-          Understand and effectively perform your role under the Three Lines of Defence principle to identify measure, monitor, manage and report risks.

-          Ensure systematic good outcomes for clients in accordance with Conduct Risk policy.

-          Support the framework of RCSA, KRI, Incident reporting and remediation, as appropriate, in accordance with the Operational Risk Management requirements.

-          Maintain appropriate knowledge to ensure full qualification to undertake the role.

-          Complete all mandatory training provided by the Bank, attain, and maintain the required levels of competence.

-          Attend mandatory (internal and external) seminars as instructed by the Bank.

-          Implement the Data Protection Framework and adopt necessary controls to monitor effectiveness of the Framework in line with local regulatory requirements and Group Standards.

Education and Experience Requirements

-       A minimum of 10 years’ experience in major banking institution or regulatory agency out of which 5 years should be in a supervisory role relating to Compliance or Internal Audit.

-       University graduate preferably with a Major in Finance, Law, Banking, Economics, Mathematics, or Business Administration (related field of study), Masters preferred

-       Professional qualifications such as CCO/CPA/CIA/CA.

-       Good oral and written communication skills (incl. report writing) in English depending on each country requirements (Arabic or French) is required.

-       Extensive Knowledge in the following areas;

• Banking and IT applications.

• Current regulations and financial instruments.

• Bank accounting procedures

• Banking products and services

• Regulatory and tax matters.

  -       Self-discipline, initiative, organizational skills & relations building skills.