Compliance & Financial Crime Testing Manager, Asia Markets
Hong Kong
  • The main purposes of the job are : (i) to conduct risk-based, independent andonsite Compliance and Financial Crime reviews (hereafter Compliance reviews ) designed to review the effective implementation in AXAentities of the Compliance, Financial Crime and Data privacy Group, Regionaland local requirements;
  • and (ii) carry out compliance oversight, monitoring andsupport to the Asia entities belonging to the INM (i.e. Malaysia, India andSingapore).

    i) Compliance and Financial Crime Reviews

    As a second lineof defense, Compliance should perform controls on a regular basis to ensure theappropriateness and adequacy of Compliance resources, procedures and systems andthe effectiveness of the internal control environment linked to Compliance,Financial Crime and Data Privacy.

    With thisobjective, the Compliance & Financial Crime Testing Senior manager willconduct annually a series of onsite Compliance reviews in AXA entities.

    It isnoted that those review will be conducted in a team made at least of twoCompliance and Financial Crime Testing Senior Managers.

    The reviews will bestructured around the following main phases :

    1.Preparatory phase :

    design and enrich Complianceand Financial Crime control programs related to all the dimensions of thereviews from various sources, both internal (standards, policies, real cases,etc.

    and external (regulatory programs, compliance literature, industry best practices,etc.)

    Notify officially theentities executive management and some key stakeholders about the objective,content and timing of the Compliance review.

    Coordination with theentities in anticipation of the onsite visit : materials to be shared inadvanced, preliminary questions and calls, agenda and logistical preparation

    2.On site review :

    The onsite reviews willconstitute the core part of the entity’s compliance reviews. To give anindication of timing, it is expected the onsite reviews to last at least oneweek, with the view of being extended when it is felt necessary, such asreviews occurring in large entities or where complexity of the topics is higher.

    During the onsitereview, the Compliance & Financial Crime Testing Senior manager will lead anumber of interviews with various stakeholders in order to get a deeperunderstanding of local processes and of the organization in order to extract andanalyse all the necessary and relevant information for the accomplishment ofthe assignment

    Compliance Controlprogram : The Compliance &Financial Crime Testing Senior manager willgo through the various dimensions of pre-

    defined Compliance control programs tocheck whether controls expectations are met, and if not document any breach.Controls intend to be risk-

    based, i.e. the Compliance & Financial Crime Testing Senior Managerwill focus first on the effectiveness of controls linked to the main Compliancerisks, as reported annually by the Compliance function

    Sample analysis. TheCompliance & Financial Crime Testing Senior manager will select for mostcontrols a sample of data related to customers, transactions, products,services, employees, third parties, and any other relevant areas to gauge andreport on the effectiveness of embedded compliance controls and adherence toGroup Compliance Standards and entities Compliance procedures.

    For instance,control will consist in checking few months after the issuance of a GroupCompliance Standard / Policy that it has been effectively locally implemented(e.

    g. new sanctions, new clause to be integrated, new ban on some business, newrules on sales suitability, etc.).

    The ability of theCompliance & Financial Crime Testing Senior Manager to extract, analyze anddraw conclusions from the right sample of data (from management systems,accounting, customers database, etc.

    will be a key success factor of theCompliance review.

    Working programs : Allthe findings of the internal control reviews will be documented and formalizedinto working programs that will be filled out in the course of the onsitereviews

    Findings will bediscussed with the entities stakeholders to ensure their accuracy and theirappropriateness from local management


    After the onsitereview, additional questions and exchanges will be organized with the entity tofinalize the review

    A synthetic report willbe designed gathering all the findings identified and locally validated.

    The report will be thenfinalized and shared with the relevant Group, Regional and local stakeholders.

    An action plan is thenexpected to be produced by the entity with detailed tasks and timing to be enforcedwithin a prescribed timing to face the issues and findings raised during thereview.

    4.Library of controls

    The Compliance &Financial Crime Testing Senior manager will enrich and maintain the library ofCompliance and Financial Crime control at any time, before, after or in thecourse of a Compliance review

    The Compliance &Financial Crime Testing Senior manager will liaise with the other regionalCompliance managers to monitor entities implementation of Compliance controlsand action plans

    5.Duration of a review

    As an indication, areview should be covered within1-1,5 months, depending of the size of theentity and the scope of topics covered

    It is expected thatadhoc reviews could be performed at any time upon request from the managementof the Group / Asia Markets.

    The ComplianceMonitoring & Testing Senior Manager could support as well any M&A duediligence by demonstrating active monitoring / mitigation of compliance issues

    It is reminded that a key component of the positionlies in the ability to challenge the substance reported by the entities and todrive the quality of the deliverables.

    The position requires some capacity tounderstand Compliance, legal issues but also to a certain extent accounting (toextract adequate data) to be in a position to locally challenge the substance.

    It also requires a certain level of assertiveness, autonomy and seniority to beable to defend he / her opinion, based on his / her actual findings, to convincelocal management and to face and manage any potential conflictual situationsthat could emerge from the review.

    Finally, the job position contributes to support thematurity of the Compliance function across the Group and to ensure an efficentrelationship with the Group and external parties, such as auditors and regulatory authorities.

    ii) Anti-Bribery and Cross-Border Business

  • Assist in the design, definition anddocumentation of effective compliance frameworks and supporting practices,policies and procedures to support organisational obligations with respect toCross Border Transactions (with a particular focus on tax evasion) AntiBribery, FATCA and CRS.
  • Facilitate andoversee the effective implementation of anti-bribery framework into allentities operating under the Asia Markets infrastructure
  • Assist in reviewingany Cross-border business application from Asia Markets entities and liaisingwith Group Compliance to seek approval Cross-border Businses
  • Taking primaryresponsibility working with the entities to develop training and communicationsmaterials relevant to the Group anti-bribery topics
  • Oversee thedevelopment and implementation of an ongoing compliance monitoring frameworkaimed at ensuring operational effectiveness of elements (identified through arobust risk assessment) of the financial crime compliance framework.
  • This compliance monitoring framework is to becoordinated and driven by the Asia Markets Corporate Centre

  • Prepare accurate andcomprehensive responses to all AXA Group reporting and ad hoc requests receivedby the Asia Markets for review by General Counsel and Head of Compliance beforerelease
  • Prepare accurate andcomprehensive reports, as required, by regional and / or local entity managementcommittees and / or executive members.
  • General Counsel and Head of Compliance oversight will be applied asdeemed appropriate.

  • Assist the GeneralCounsel and Head of Compliance with the preparation of annual complianceoperating plans highlighting matters of anti-
  • bribery or cross-border topics thatrequire attention

  • Around 5-10years experience of working in Compliance, Financial Crime, Internal orExternal Audit or in Sales, Distribution or Underwriting in insurance
  • Availabilityfor travelling
  • Legal backgroundis a plus
  • Fullyproficient in English
  • Assertiveness
  • Have agood understanding of, and build a good relationship with, the other controlfunctions (Risk and Audit) and with the Group
  • Would you like to wake up every day driven and inspired by our noble mission and to work together as one global team to empower people to live a better life?

    Here at AXA we strive to lead the transformation of our industry. We are looking for talented individuals who come from varied backgrounds, think differently and want to be part of this exciting transformation by challenging the status quo so we can push AXA -

    a leading global brand and one of the most innovative companies in our industry - onto even greater things. In a fast-evolving world and with a presence in 64 countries, our 166,000 employees and exclusive distributors anticipate change to offer services and solutions tailored to the current and future needs of our 103 million customers.

    AXA Asia is a market leading insurance player offering a differentiated composite proposition in Life and General Insurance with operational presence in Hong Kong, Singapore, Indonesia, China, India, Malaysia, the Philippines, and Thailand.

    AXA Asia is part of the AXA Group, headquartered in Paris and a worldwide leader in insurance and asset management with a presence in 59 countries.

    AXA Asia is committed to creating a sustainable, long-term business for our employees, customers and shareholders.

    We’ll give you :

  • A competitive salary and benefits package
  • Medical cover and dental plan
  • Attractive pension plan
  • Rental reimbursement scheme
  • Extensive learning and development opportunities
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