Job Description

Overall Purpose of the Position

The term Customers refers to - Personal – Applications

·     To evaluate and approve Onboarding Requests using the risk- based approach as established in the PMLFTR, analysing documentation collected, leads and information arising from databases and other sources, investigations, and providing recommendations to the Manager for acceptance or rejection of the proposed business relationship.

·     To analyse the source of funds and source of wealth information collected from the Applicant and other sources using statistical techniques or otherwise escalating should suspicious behaviour to arise.

·     To provide leadership and technical competence in the handling of the customer onboarding procedure to assure compliance and guide relationship managers as may be appropriate.

·     To ensure that the risk assessment and quality of data obtained for the customer, relationships and connections are accurately verified as per the Bank’s regulatory obligations and to assure that all supporting documentation is appropriately collected.

·     To carry out evaluations of Personal Customers.

·     To liaise with other Officials and Units within the Bank and with Applicants and Customers as necessary.

.

Operational Responsibilities

• Assess under which customer cohort the respective application is assigned and ensure that all applicable regulatory documents are collected, assigning cases to analysts according to availability and application priority.
•  Endorse the veracity and validity of documents collected, and corroborate the information provided with official sources and leads arising from research.
• Undertake a careful risk assessment of personal customer applications by analysing the source of funds and source of wealth, transactions and assuring that information collated from account statements and other researched sources are consistent with the Customer Due Diligence Form submitted by the customer and leads arising from research.
•  For Personal customers connected with Corporate Companies and other non-personal entities/firms, analyse and endorse the Memorandum and Articles to calculate the percentage of direct and indirect Ultimate Beneficial Ownership to address the necessary due diligence as per best practice outlined in the PMLFTR.
•  Verify the collation of documentation, review and assessment of customers consistent with risk-based parameters determined in the PMLFTR, FATCA/GATCA (CRS), Depositor Compensation Scheme or any other regulation that may be established to be reviewed from time to time.
• Issue instructions to relationship managers on the methodology of on-boarding, identifying issues and special clauses to be addressed in Customer Due diligence forms, in borderline cases develop a business case for presentation to COMPLIANCE COMMITTEE and in the case of rejection, assist in the management of communications with the customer.
• Ensure that a comprehensive due diligence process has been conducted in line with the applicable legislation.
• Lead the business and system requirements initiatives, coordinate the regression testing and ensure a successful implementation for the KYC Project and any other projects as assigned from time to time.

General Responsibilities

• Develop a sound working knowledge of the local regulatory framework and the applicable EU Directives and Regulations, recommend updates to department manuals, procedures and forms in line with the regulatory framework.
• Conduct and maintain excellent working relationships with regulatory bodies, service providers and external consultants on matters linked to Compliance projects, processes and procedures.
• Collaborate with colleagues from different teams within the Function as well as other Units or Divisions within the Bank on matters within the remit of the Customer Profile Unit.
• Prepare and conduct internal compliance related training initiatives across departments and units and engage in continuous professional development.
• Champion the ongoing development of a Compliance culture within APS Bank by promoting adherence to policies, guidelines and procedures at all times.
• Perform standard office tasks including processing mail, answering phone calls and emails, organising and filing all customer documents, and undertake any other duties that may be reasonably assigned from time to time.

Qualifications, Skills & Competencies 

 Mandatory

 Skill

• Excellent verbal and written communication skills.
•  Accountable, Organised, Meticulous and able to handle tight deadlines.
• The ability to analyse and interpret information diligently
•  Be a team player while still being able to work independently
•  Excellent analytical troubleshooting and interpersonal skills

Experience

• -

 Qualification

• Ideally Bachelor’s Degree, MCAST Diploma or recognised AML/CFT Certification at MQF Level 5 or higher

Desirable

 Skill

•  Be computer literate with MS products and familiar with researching on the Internet.

 Experience

• Previous Compliance experience is preferable but not essential.

 Qualification

• Compliance and/or Anti-Money Laundering CFT qualification will be considered an asset.

Position level (1 being the highest level)

1. Head of Department
2. Managerial & Specialist Positions
3. Middle Management & Specialist Positions
4. Technical & Clerical Positions