Regulation, Compliance & Anti-Financial Crime
Regulation, Compliance and Anti-Financial Crime (AFC) protects the integrity and reputation of Deutsche Bank. It manages the Bank’s risks and help to avert unintentional rule breaches and conflicts of interest.
At the same time, we also advise the bank on ethical conduct and governance issues and keep the bank up to date on regulatory and political challenges.
ROLE AND RESPONSIBILITIES :
There are a number of key responsibilities within the Wealth Management (WM)Compliance function. Each of these responsibilities is important to the overall success of the role and Wealth Management Compliance will be held accountable for key deliverables.
Risk Appetite When advising on compliance and regulatory risk, WM Compliance should always advise in a manner consistent with local regulations and the Bank’s Values and Beliefs.
Advice should take account of, among other things :
Results of risk assessment;
Issues identified from Assurance programme;
Impact of regulatory change, readiness for implementation of required changes and awareness of new requirements;
Knowledge and understanding of industry related issues and themes (at a local, regional and global level);
Knowledge and understanding of regulatory issues and themes (both local and extraterritorial);
Lessons learned from internal issues including investigations, litigation, incidents and audit issues;
Appreciation of business strategy of the relevant business function; and
Robustness of business governance and systems and controls.
Conduct issues and related matters provide advice and guidance to the business and infrastructure functions on conduct related matters in line with regulatory standards, Bank policies and Values and Beliefs.
This can be oral or written but needs to be recorded;
New Product Approval ensure each new proposed product meets regulatory standards and Bank policies in all impacted locations and is in line with Values and Beliefs;
New Transaction Approval ensure transaction meets regulatory standards and Bank policies in all impacted locations and is in line with Values and Beliefs;
Compliance Policies and Procedures ensure Compliance policies and procedures for business line reflects regulatory standards and Values and Beliefs and the Bank’s minimum standards (also provide appropriate subject matter and drafting support to Compliance policies and procedures managed centrally);
Cross-divisional or cross-border issues : ensure adequate knowledge sharing with interested Compliance colleagues in other locations or covering other business lines;
Business Line Procedures provide input and guidance based upon regulatory standards, Bank policies and Values and Beliefs;
Training and Education work with training team to create and deliver risk-based training programmes with particular focus on regulatory change and emerging regulatory and business line issues and provide input to training team on upcoming needs and planning calendar for training rollout;
Level 1 Controls provide guidance to the business on adequacy of existing controls and medium / long term requirements;
Complaints work with the business to respond appropriately to complaints and ensure lessons learnt are incorporated into DEUTSCHE BANK policies and procedures;
Whistleblowing investigate any such allegations together with investigations team as appropriate;
Governance actively participate in and provide effective input and guidance to all relevant DEUTSCHE BANK governance committees;
Escalation escalate items requiring Compliance management’s attention (for instance, risk of missing effective regulatory change dates, activities that run afoul of regulation or the Bank’s Values and Beliefs, or items close to / outside of compliance risk tolerances) in a structured and collaborative manner;
Report on and prepare, as necessary, management information for Compliance Management and Business Management report key relevant regulatory and reputational issues on a regular and timely basis or as requested by management and do so in a structured manner;
Reputational Risk identify issues for escalation to Reputational Risk Committee and provide advice and guidance as relevant for other issues referred to RRC; and
Cultural Change act as an ambassador for our / the bank’s Cultural Change, including the Values and Beliefs
Risk Assessment and Assurance
Level 2 Controls provide guidance to Assurance, MCT, CTS, Surveillance and similar teams (collectively referred to as Assurance teams’) in developing their respective programmes (also provide guidance with respect to resourcing related priorities);
Act as an effective intermediary to the business to support Assurance and Central Compliance functions’ communication with the business;
Where no such Assurance teams exist onshore, provide an effective interface with Assurance teams in other locations as necessary;
Completion of CCF / MaRisk Assessments undertake risk assessment on a timely basis in-line with global requirements;
Effective partnership with Assurance teams
Jointly own the overarching assurance plan and provide advice on scope and priority of work based upon potential internal and external issues;
Primary point of escalation for issues identified by Assurance teams;
Co-own the Assurance message (i.e., one voice for Compliance)
review Assurance teams work product to proactively identify potential areas of risk requiring focused review and provide targeted and regular fee Deutsche Bank ack designed to enhance the effectiveness of the Assurance program;
Provide effective assistance to Assurance teams in the follow up with Business on issues on a timely basis and ensure issues are being tracked and action plans are implemented; and
Undertake or support ad hoc desk reviews as required
Investigations provide direct and indirect support, direction and guidance as required.
Except where relationship sits with another function / department, own the regulatory relationship for relevant business line -
liaise with local management, business divisions and Compliance colleagues including Regulatory Compliance team if that team exists locally to plan, support and manage regulatory inspections and examinations, specific regulatory requests and remediation plans;
Where responsibilities include regulatory advocacy agree delineation of roles with Country Management, Legal and regional GRAD team;
Participate in key regulatory meetings for relevant business line; and
Identify key issues for reporting to regulators and ensure that these are communicated to regulators on a timely basis including appropriate liaison with Compliance, Country Management, Business Management and the Regulatory Compliance and GRAD teams as well as Corporate Governance Teams as appropriate including co-
ordination of message to trilateral regulators.
Regulatory Change and Implementation
Work closely with GRAD and Regulatory Change team as well as the CCF / MaRisk Team;
Assess impact of potential regulatory change;
Provide input to GRAD and Regulatory Change team in relation to regulatory reform;
Advise business on impact of regulatory change;
Ensure business updates policies, procedures and controls as a result of regulatory change; and
Highlight potential non-compliance and escalate accordingly.
Provide oversight and direction for all regulatory related projects (including remediation projects also) for their area of responsibility;
Oversee key milestones and deliverables and escalate risk at meeting material project deliverables;
Work with relevant business line to address areas of concern; and
Provide input and support to Project Management Team as required.
Financial Crime AML, Sanctions, ABC and Fraud
Awareness of key Financial Crime related matters relevant to business line;
Where applicable, provide regular updates to local management on Financial Crime related matters;
Provide input into Risk Assessment process and awareness of results; and
Identification and reporting to Financial Crime team where changes to business risk profile.
Experience and Qualification Required
knowledge of Hong Kong banking regulations, SFA rules, etc. relating to the regulated activities of wealth management, and dealing in securities as well as familiar with the FAA laws, rules and regulations;
In-depth knowledge of traditional and alternative wealth management products
Ability to communicate clearly and effectively on local regulatory matters and outsourcing issues to key stakeholders at all levels;
Ability to work under pressure and within tight deadlines with no loss of accuracy;
Proven analytical skills;
Good organizational skills, including an ability to prioritize effectively
Ability to liaise effectively and build trusted adviser relationship with Business
Attention to detail.
Persistence in dealing with issues.
Prepared to make difficult decisions.
Ability to deal with challenging situations.
Minimum 8 years of relevant experience; preference will be given to candidates with proven experience in the wealth management compliance.
Relevant university degree
Deutsche Bank offers a challenging and rewarding career where your contribution is valued and rewarded. We have an inclusive and friendly working environment coupled with excellent facilities and benefits.
Deutsche Bank is an equal opportunity employer who seeks to recruit and appoint the best available person for a job regardless of marital status, sex (including pregnancy), age, religion, belief, race, nationality and ethnic or national origin, colour, sexual orientation or disability.