AD Group AML

Associate Director, Model & Rules Oversight, Group AML(India, Poland, Malaysia)

Job Summary

The role is responsible for providing technical oversight of Models and Rules utilised within the Compliance and Financial Crime Risk (CFCR) management processes (e.g. transaction monitoring, screening) to ensure that risks related to such solutions are identified, understood and managed. The role provides oversight of FCC models, ensuring they are developed to be robust, fit for purpose and reflect financial crime risks appropriately. The role holder will also provide technical review and challenge of risk-based rules / deterministic quantitative methods (DQMs) used in the management of financial crime risks.

Background:

The Models & Rules Oversight (MRO) team sits within the Group AML 2nd Line of Defence (2LOD) function. The team is responsible for providing technical review and challenge of rules / deterministic quantitative methods (DQMs) deployed within FCC processes as well as advisory support to the 1st line in the roll out and maintenance of models. Through such reviews the team ensures that the methodologies, assumptions and logic used to develop and deploy risk-based rules are fit for purpose and that risks to the FC controls are identified. The team also works in conjunction with the relevant Risk Framework Owners to provide oversight on the models and rules are compliance with internal standards (i.e., CDD, Group Transaction Monitoring, Screening, Data Management & Responsible AI, Group Model Risk Policy and other CFCR policies, as applicable). Additionally, the team organises the FCC Model Assessment Committee and provides ad hoc support to country and business teams to review matters relating to algorithms / settings within models and rules.

The role-holder is expected to liaise with various stakeholders from 1LOD and 2LOD in different stages of the review process to ensure identification and understanding of the FC risk, and that the FCC Model Assessment Committee is informed to enable appropriate oversight.

Key Responsibilities

Strategy
•    Support the 1LOD in each stage of the model life cycle and governance of CFCR models and provide effective review & challenge to development teams.
•    Analysis of algorithm design, development logic, performance evaluation, implementation logic.
•    Execute reviews in collaboration with other members of Group AML team and other 2nd line teams (where applicable) to ensure holistic review of FC processes with consideration of model/rule inputs as well as wider integration into FCC processes.
•    Support Group AML colleagues on implementation of FCC Standards in aspects relating to models and rules.
•    Identification and impact analysis of risks (model, data, operational) within rules and algorithms
•    Advise on model & rule performance as well as performance testing regime, using statistical approaches and communicate such in a manner that is understood both by technical and non-technical audience.
•    Liaise with Group AML Policy team and Model/Rule owners to ensure appropriate interpretation of requirements affecting models and rules.
•    Support the model validation process by advising on issues and evaluating them from FC risk perspective.
•    Support local audit and regulatory reviews of rules/models.

Business
•    Liaise with business, advisory and country teams or other 2nd line teams to ensure understanding of risk emergence is reflected in models/rules, providing recommendations on design, feature logic and model performance evaluation.
•    Collate users or business or risk owners view to ensure that the risks are understood and appropriately reflected in models and rules within FC processes. This includes opining on whether the approach to data sourcing is appropriate and providing insights through data analysis to translate user requirements to defensible and sustainable approaches.
•    Responsible for supporting the validation activity performed by Group Model Validation (GMV) in accordance with the prevailing Group and Model Family Standards. Providing the relevant FC understanding on model issues and concerns raised to ensure these are communicated properly to the 1LOD.

Processes
•    Ensure review process for models and DQMs is conducted and documented according to prevailing standards and procedures.
•    Provide oversight across the different stages: development, implementation/maintenance, and validation process ensuring that all FC risks are understood and mitigated or escalated to the FCC Models Assessment Committee.
•    Identify the required data, analytical and technology infrastructure required to effectively execute reviews.
•    Perform periodic reviews of outstanding issues arising from the independent reviews and ensure that these are tracked to completion or if it requires escalation to the FCC Model Assessment Committee.

Skills and Experience

People & Talent

•    Support the effective management of resources in the team by escalating show-stoppers to team management
•    Keeping abreast of internal developments and external research to ensure the team remains updated on latest techniques.
•    Seeking development opportunities that would provide personal growth and contribute to team’s success

Risk Management

•    Conduct quantitative assessment to determine impact of issues for risk acceptance decisions or provide an FC lens on issues raised by other review teams.
•    Responsible for identifying, assessing, monitoring risks that arise through the independent reviews of models and rules.
•    Advising on control and mitigation of risks identified.
•    Ensure appropriate escalation of issues to relevant parties, setting and tracking clear remediation plans.
•    Ensure a full understanding of the risk and control environment in area of responsibility

Governance

•    Provides structure to the project and enforces rigorous project governance
•    Ensure team’s compliance with the prevailing control processes
•    Awareness and understanding of the regulatory framework in which the firm operates, and the regulatory requirements and expectations relevant to the role.

Qualifications

• EDUCATION     DEGREE LEVEL (QUANTITATIVE)
• LANGUAGES     ENGLISH