Sanctions Manager

Role Purpose:
The Job holder supports Head of Sanctions in meeting Sanctions obligations by
providing an active support in the implementation of Sanctions and Financial
Crime policies in compliance with Central Bank of Egypt regulations and Group
's Global Policies and Procedures.
The jobholder assists the Head of Sanctions to; identify Sanctions and
compliance risks, foster a compliance culture in the Bank, optimize relations
with the Regulators, protect the reputation of the Group and comply with
applicable Group policies and standards and local laws and regulations in
order to prevent criminal sanctions.
In the execution of Sanctions risk steward responsibility, the job holder must
independently handle the tasks assigned to him/her and be able to take
decisions on matters within their designated authority. The job holder must be
able to independently analyze and critically evaluate the responses received
without much supervision and escalate as appropriate.
The person will be acting as a risk steward to all relevant stakeholders on
Sanctions and Financial Crime related matters providing advice and guidance on
their assigned area to the relevant business areas and country compliance
within Egypt.
Principal Accountabilities: Key activities and decision making areas
Impact on the Business
Support Management in meeting HSBC's regulatory and Group requirements on
Sanctions risk by:
* Managing and coordinating sanctions compliance for HBEG
* Reviewing any new/amended material laws, rules and regulations and Group Policies, assess their applicability to the business areas and guide the business accordingly ensuring all appropriate processes and procedures are amended to comply.
* Reviewing and take decisions with respect to escalated payments by GSC or business for sanctions for Egypt and escalations by country compliance within HBEG
* Assisting Head of Sanctions and country Compliance in their responsibility for complying with all relevant Laws, Rules, Regulations and Group policies related to Sanctions and AML
* Evaluating and monitoring existing procedures and develop new procedures, systems and controls with specific focus on common systems, off shoring initiatives to minimize the risk of the firm being used for financial crime and ensure the business is compliant with current anti-money laundering and sanctions requirements
* Prepare regulatory filings and correspond with regulatory agencies as agreed with the Head of Sanctions Compliance and Senior Manager Sanctions.
Customers / Stakeholders:
* Proactively assist Head of Sanctions in supporting business and country compliance functions to operate in a compliant manner
* Provide guidance to business areas on sanctions risk and exposure related to customer account opening and transactional activity
* Provide guidance to HBEG project teams and compliance representation on any sanctions related systems project for the country.
* Provide guidance to GSC on implementation on Sanctions related Group and or regulatory related requirements.
Leadership & Teamwork:
* Provide guidance and training the Area Compliance Officers on implementation of sanctions compliance within HBEG.
* Provide advice on compliance AML & CTF/Sanctions issues that arise through the country compliance functions
* Liaise with GMO Compliance and GMO functions on sanctions related matters, reporting of KPIs and other matters requiring HBEG representation
* Support the Sanctions team by providing back-up coverage for leave and vacation

Operational Effectiveness & Control:
* Conduct reviews for Branches and Business areas for AML/CTF/Sanctions compliance. Produce review reports and make recommendations.
* Support Head of Sanctions Compliance on country compliance reviews
* Raise exceptions through IRIS reporting system and make decisions on reporting to senior management. Ensure a review all cases on a quarterly basis and provide updates where necessary or close cases where action completed.
* Support efforts to proactively drive the KYC improvements to support sanctions compliance
* Immediately escalate to Head of Sanctions as applicable any material breaches or potential breaches of Laws, Rules and Regulations

Major Challenges:
* Balancing Business opportunities and needs with complex regulatory requirements
* Balancing local regulatory requirements with international standards and Group requirements
* Evaluating reputational AML, CTF and Sanctions risk arising from customers and transactions
* Recognition of the Sanctions and AML priorities by business management
The environment for anti-money laundering, sanctions and counter terrorist
financing has changed significantly in recent years. The requirements from the
Bank's lead regulator, local regulators and enhanced Group standards present
an increased burden on customer identification, transaction scrutiny and risk
based reviews.
The job holder is required to work closely with the Head of Sanctions
Compliance in implementing Sanctions, AML andCTF processes and monitoring
requirements across all business lines covering all HBEG.
Role Context:
* Operates across multiple jurisdictions and business lines
* Understanding Group, International and local regulatory requirements and recognition of Sanctions, CTF risk
* Complex international sanctions environment
* Complexity arising from sensitivity due to political and economic structures.
The Group's global policy is to comply with high standards of Sanctions
practice in all markets and jurisdictions in which it operates. This relates
to abiding by local regulations as well as Group directives.

Failure to comply with Sanctions and CTF regulations can have significant and
material adverse consequences for the HSBC Group, HBEG and certain
individuals. These include fines, firms being closed, business being unwound,
loss of customer confidence and criminal prosecution. All of these have an
adverse effect on the Group's reputation.
Management of Risk:
* Review of different escalations received by Sanctions team
* Provide adequate and timely advice to all business and Compliance stakeholders
* Adhere to policies and procedures to manage and reduce customer and transaction related sanctions exposure in HBEG..
Observation of Internal Controls:
* Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.
* To discharge the (Compliance Officer) accountabilities set out in the Compliance Officer Handbook by pro-actively assisting management in identifying and containing compliance risk; monitoring, reporting and certification; fostering a compliance culture and optimizing relations with Regulators
* Adhere to Group Compliance FIM and HSBC Global Policy and Principles on Anti Money Laundering and Sanctions

Requirements
Knowledge & Experience / Qualifications:

• The job holder must have at least ‎3 years experience in Compliance or Risk management roles.


• Background in Payments, Screening or Trade is preferable.


• Experience of the full range of personal and commercial banking services and have a strong subject matter expertise in the area of Anti-Money laundering including regulatory environment and regulations.


• The ability to multi-task across many fields involving potentially complex projects and multiple teams


• Experience of people management preferable


• Proven communication and influencing skills with the ability to communicate and in writing at all levels


• An excellent command in English