Ensure that AML/CFT Risks are timely addressed and mitigated and all controls are in place to encounter risks emanating from money laundering and terrorist financing through use of banking channels failing which you are accountable in front of senior management. Ensure adherence to law 106/2013 concerning money laundering and the financing of terrorism and its executive regulations, CBK, bank policies, other International regulatory bodies’ instructions and any other ministerial/local decrees.
1. People Management Manage, motivate and develop individual employees and the team in line with people policies & practices. Communicate operational procedures.(If required)
2. Corporate Governance and Compliance Work fully within risk policies and procedures and compliance regulations and ensure all divisional activities comply with corporate governance & regulatory/legal frameworks
1. Ensuring having sufficient operational independence to carry out AML duties by having direct access to customer identification data and other relevant information of financial transactions, customer records and due diligence measures.
2. Ensure AML policy, procedures, guidelines and systems are updated to be in line with AML law 106/2013issued by state of Kuwait and Ministry Resolution No (5) of 2014 with respect to the executive rules regarding the Executive of UN Security Council Resolutions issued pursuant to Chapter VII of the UN charter with respect to terrorism and finance of terrorism, and all other relevant rules and regulations.
3. Ensure comprehending and implementation of AML/CFT CBK instructions and Basel recommendations.
4. Ensure fostering relations with the local law enforcements such as CBK, Kuwait Financial Intelligence Unit, and Capital Market Authority; as well as acting as AML representative in all projects assigned by Head of AML/CFT externally and internally.
5. Ensure that all bank’s operations, in Kuwait, are performed in line with law 106/2013, CBK Executive regulations, directives, KFIU circulars, ministerial resolutions No.5 /2014 to protect the bank and its branches from any attempt of money laundering and terrorist financing.
6. Assist AML/CFT management in evaluating and implementing the required system controls and assigning resources to ensure that bank’s operations are in line with the latest issued Ministry Resolution No (5) of 2014 with respect to the executive rules regarding the Executive of UN Security Council Resolutions issued pursuant to Chapter VII of the UN charter with respect to Al-Qaida & ISIL (Da'esh) and Taliban sanction lists (Individuals &Entities).
7. Ensure immediate actions are taken pertaining to any freezing of assets instructions received from the national committee or released in the official gazettes and UN websites, and respond within the specified time frame.
8. Assist Head of AML/CFT in submitting periodical reports to Board of Directors confirming bank-wide adherence and compliance with CBK rules and regulations concerning the new AML Law 106/2013, its executive directives, and other regulatory bodies’ directives including CBUAE, specifically details of STRs (suspicious transactions Reported to KFIU) and any other identified AML/CFT issues which required BODs recommendations and decisions.
9. Manage all BOD and external authorities’ reports.
10. Ensure that business areas are adhering to the banks policy and guidelines while opening new accounts and are completing requisite documentations and screening against blacklist via complete a sampling review periodically.
11. Ensure managing and following up with responsible business areas to complete implementing required preventive measures to close any observations and systemic procedural weaknesses either resulted from internal or external audit findings related to AML/CFT
12. Manager AML unit MIS for all reporting purposes, as well as ensuring that AML system issues are handled efficiently and appropriately with vendor support.
13. Provide required guidance and support pertaining to system monitoring and thresholds requirements.
14. Provide assistance and guidance to other Divisions/Units on AML/CFT and sanction issues.
15. Assist in responding to any money laundering queries and questionnaires received from other correspondent banks.
16. Ensure availability of business parameters in the anti money laundering software including OFAC and FATF blacklists and to conduct continuous tracking and analysis of data generated by the software.
17. Assist AML/CFT management to ensure that AML/CFT monitoring tools and systems are functioning trouble free and take appropriate approach in coordination with IT division and vendor for solutions.
18. Monitoring AML calendar of reviews/checks as assigned by the Head of AML/CFT.
Job Success Factors
· Effective review and update of AML/CFT policies and procedures
· Effective investigation and reporting actions in line with procedures and timelines
· Effective AML/CFT Training delivery to all business stakeholders
· Adherence to bank AML/CFT policy and procedures and all local law enforcement agencies.
· Timely and relevant closure of compliance issues
· Closure of all Internal/ External AML/CFT issues
· High quality of reporting skills
· Compliance with operational procedures, instructions, and risk management policies.
· Analytical skills