Local Compliance Financial Security Officer

1. High Risk Escalations:

• To review PEP and other higher-risk clients, to assess and agree appropriate level of risk for each referral - and to ensure the Compliance Team log (or other relevant record) is updated and maintained accordingly, to ensure appropriate audit-trails for decisions.
• Review contract and deal specific documentation to assess for the presence of financial crime compliance risk (e.g. sanctions, bribery, money laundering, etc.), to identify options to mitigate identifiable risk (in consultation with other Corporate Governance specialists).
• Represent Compliance in Product Development Committee, New Activity Committee (NAC), Client Acceptance Committees and other internal forums related to higher-risk clients, products and risk in the operating/business environment.
• Reviewing and assessing alerts generated by the Group’s monitoring systems (e.g. SUN) where transactions or persons/bodies are referred for review and assessment of money laundering or sanctions risk.

2. Advisory:

• Provide advice consistent with (and ensuring appropriate application of) Group policies and applicable legal and regulatory requirements, particularly in relation to anti-money laundering (AML) and financial sanctions, anti-bribery, and related AML or Financial Crime policies and procedure.
• Maintain up-to-date awareness and understanding of Vietnam requirements, particularly in relation to Money Laundering Regulations (or equivalent), Financial Sanctions and FCA Handbook (in relation Financial Crime) and FCA Financial Crime Guidance (i.e. ‘core knowledge’).
• Applying understanding of core knowledge when supporting/advising the business and support functions.
• Competently demonstrate key AML analysis and articulate clear guidance to inform opinion on how best to identify and respond to financial crime risk, including, inter-alia, via formal reporting to the BoD and Regional Office.
• Provide timely update/analysis to the BoD for business opportunities/limitations when there is change on the regulatory regime, and monitor the implementation of action plans for new/updated regulations in Financial Security area properly.

3. Training and Guidance:

• Localize, enhance and implement compliance policies/procedures related Financial Security from BNP Paribas Cardif.
• Support the Company’s development and delivery (where necessary) of financial crime training.
• Key financial security compliance contact for the business, particularly in relation to core knowledge areas.

4. Investigation and internal reporting:

• Report to the Nominated Officer/Investigations team any knowledge or suspicion of money laundering or terrorist financing using the Company’s internal escalation process.
• Ensure up-to-date awareness and application of other internal reporting requirements covered by Group Policy and Vietnamese Law/Regulation with regards to financial crime.
• Timely submit compliance reports in relation to financial security to Regional Office/Head Office
• Report any breaches of legislation or Group policy using the Group’s breach reporting procedure and escalate issue to the appropriate area.

5. Other (Ad hoc):

• Review and form a fact-based opinion in respect of any negative or detrimental news referred to Head of Corporate Governance for consideration.
• Maintain highly accurate records and to ensure any Management Information produced is of the highest standard.
• Ensure Management is made aware of all pressing issues in a timely fashion.
• Provide support to regular and ad-hoc internal projects which require subject matter specialist input and advice/guidance (re financial crime).
• Ensure appropriate audit trail for all advice/key decisions
• Other duties as assigned by Head of Corporate Governance and Head of Compliance BNP Paribas Cardif Asia.