Address
Form of work
SalaryDescription of the Business Line or Department
The Compliance Service Unit (CPLE) is responsible for the definition and consistency of the compliance risk prevention and control system, and for coordinating the framework aimed at preventing, identifying, assessing and controlling compliance risk.
In conjunction with the Business Units and other Service Units (BU/SUs), CPLE performs the following tasks with respect to compliance risk:
defining and implementing the overall normative framework of the Compliance service and monitors its implementation;
defining procedures and implementing a framework to ensure compliance with respect to compliance risks;
awareness-raising among Group employees regarding compliance risk and the strengthening of the compliance culture within the Group;
mapping and analysing Group compliance risk and general vigilance regarding issues likely to harm the Group's reputation or that of one of its activities;
performing the second-level control and supervision of the framework, including independently assessing compliance risk management within the entities/activities with a major impact on the Group's risk profile, and individually with respect to regulated employees, in compliance with the applicable regulations;
monitoring relations with supervisory and regulatory authorities, and representing the Societe Generale Group to these authorities, not including supervisory and regulatory authorities where the Legal function (SEGL/JUR) organises and coordinates the monitoring of these relations, in particular the Autorite de Controle Prudentiel et de Resolution (ACPR) and the European Central Bank (ECB);
consolidating and monitoring significant compliance events in the entities.
Summary of the key purposes of the role
The Financial Crime Unit ("FCU") provides business management within SG London Branch ("SGLB"), and SG International Ltd ("SGIL") (collectively these legal entities will be referred to as "SG London") with technical advice on the management of the firms' money laundering/terrorist financing, anti-bribery and corruption ("ABC"); sanctions and embargoes ("S&E"); and Tax Evasion and Facilitation Offence ("TEFO") risks. In addition, the Unit undertakes an oversight role to assist management in the assessment of the effectiveness of the policies, procedures and controls designed to mitigate these risks.
Key purpose of the role:
To act as a Sanctions & Embargoes ("S&E") subject matter expert for SG London, reporting directly to the Sanctions & Embargoes Compliance Manager.
To assist in the monitoring of the effectiveness of SG London's Sanctions Compliance Program, and ensure that sanctions related policies, procedures, systems and controls are being complied with, are working effectively and are properly embedded within SG London.
To assist in the provision of up to date and accurate international sanctions advisory services to the business on new and existing opportunities for SG London
Key responsibilities
Act as an S&E subject matter expert and point of contact for SG London. Providing support, advice and guidance on S&E matters as required e.g., material risk and complex S&E issues;
Receiving, investigating and reporting S&E related issues escalated by management or staff. Where required this will include reporting to relevant competent authorities and internal incident reporting e.g., OFSI asset freeze, OFSI sanctions breach, OFSI licence application;
To assist the Sanctions and Embargoes Compliance Manager in the review of the risks faced by SGLB and SGIL through both formal and informal risk assessment methodologies;
Assist in the identification of sanctions related training needs, developing appropriate tools, drafting training decks and delivering face-to-face training;
Assist in the maintenance of the SG London S&E related procedures and guidance notes to ensure compliance with UK legislation and Group Policy.
Assist in the management of situations where SG London is unable to apply SG Group policy and controls due to the independency of the UK's sanctions regime.
Assist the Sanctions and Embargoes Compliance Manager in preparing for governance meetings for both SGLB and SGIL, inclusive of the collection of appropriate Key Risk Indicators and other relevant management information;
Act as an escalation point for new and existing client due diligence files where material sanctions risks and complex issues are identified;
Assessing the impact on SG London of forthcoming changes in sanctions regulations;
Developing and strengthening global relationships with the business heads, sanctions teams, business units and service units to promote best practice to ensure there is a clear understanding of the UK's sanctions requirements;
Assist the Sanctions and Embargoes Compliance Manager with all local and group projects and processes which impact SG London;
Draft and execute controls to ensure that sanctions policies and processes are being adhered to;
Support the Sanctions and Embargoes Compliance Manager with preparation for regulatory, internal audit and compliance assurance reviews;
Assist in the review of sanctions clauses in collaboration with the legal department, to ensure SG London is sufficiently protected;
Represent SG London in partnership with the Sanctions and Embargoes Compliance Manager at relevant S&E industry bodies/forums;
Perform all duties in accordance with the principles outlined in the SG London Code of Conduct, as well as the policies and procedures relevant to your responsibilities, to ensure that you adhere to a culture that treats clients fairly and focuses on the long-term sustainability of client relationships.
Profile required
Competencies
Individual contributor competencies as defined in the SG Leadership Model
Experience in Wholesale/Corporate Banking
Team Spirit and Collaboration
3-5 years sanctions experience in a role requiring knowledge of the regulatory and legal requirements issued by US OFAC, EU, UK OFSI and the UN.
Demonstrable experience in providing guidance on complex S&E issues
Communication - written and verbal to all levels of the organisation and to external third parties including; third party vendors and local governmental regulatory offices
Decision making - consider and recommend escalations to Senior Management/Head Office, regulators and relevant government agencies, having conducted autonomous investigations
Influenc
