Financial Crime Threat Mitigation (FCTM) focuses on the specific financial crime threats the firm faces now and in the future, pioneering the techniques and technology that protect our business, our customers, and the many communities in which we operate from the harms associated with financial crime. FCTM harnesses intelligence, analytics, technology, investigation, information sharing, and public-private partnership to achieve this end, always seeking the most effective and efficient means. FCTM is also partnering with Financial Crime Compliance to build the case for a more efficient and effective regulatory approach by defining a potential new regulatory landscape based on practical, tested innovation and serving as a thought leader in the ongoing public debate on the future of regulatory compliance.
The jobholder is positioned in one of FCTM's five global functions aimed at mitigating the harms associated with financial crime: Investigation. In this role as the Senior Investigator, Complex Investigations, the jobholder:
· Operates within the firm's complex investigative programs across regions, and countries related to fraud, anti-money laundering, countering the financing of terrorism, sanctions, anti-bribery and corruption. Ensures the quality and consistency of the investigations and the adequacy of the resourcing across the investigative program.
· Takes part in Investigations across regions, and countries to conduct complex, proactive, intelligence-driven investigations, bringing together and drawing upon resources in other investigative functions where the nature of the investigation spans multiple geographies or financial crime types.
· Communicates information on the most significant and sensitive investigations and related mitigating actions to Regional and Group senior management to support and facilitate a strategic appraisal of the relevant risks.
· Identifies and escalates the most significant and sensitive investigations to ensure appropriate prioritization, resourcing, and investigative strategy.
· Operates within a systemic capability to refer investigative findings and recommendations to other parts of the firm for follow-on action to mitigate the identified financial crime risk, track the response, and ensure appropriate governance.
· Provides the subject matter expertise necessary to inform the work of other parts of FCTM, including but not limited to innovations in analytics, identification of typologies, policies and procedures, the engagement strategy, training, and a potentially more effective and efficient regulatory landscape.
· Supports the Global and Regional Head of Complex Investigations in communicating the most significant and sensitive investigations and related mitigating actions to senior management to support and facilitate a strategic appraisal of the relevant risks.
· Establishes seamless, trusting and mutually supportive relationships with the other components of FCTM, FCC and GIIG.
Impact on the Business
· Works with Complex Investigation specialists across the region and countries to identify and investigate financial crime threats to the firm.
· To support strategies and initiatives among reporting teams in support of FCR objectives and ensure for the effective execution of Complex Investigations within FCTM.
· To support execution of the regional investigative procedures or approved country variances, which are designed to ensure the operational effectiveness of the investigative capability.
· To ensure effective information sharing across FC Investigation, FCTM, and with other parts of the organization.
· To ensure investigative findings are effectively communicated to other parts of the organization for follow-on mitigation action, and results recorded.
· To escalate significant financial crime threats and management issues to senior leadership so appropriate action can be undertaken in response.
· To undertake production and issue Management Information to senior leadership.
· Proactively identify key emerging financial crime threats within the jobholder's functional area and interface with other global functional areas.
Customers / Stakeholders
· Maintains relationships with key internal stakeholders across Global functions, lines of business, regions, and countries.
· Helps foster external relationships with key public sector partners and peers.
· Manages the sharing of information and creation of feedback loops across the firm to continuously adapt and improve our financial crime controls and support the business in their first line responsibilities.
· Works within the capability necessary to manage the Investigation response to high priority financial crime threats requiring a coordinated response across Regional FCR functions, lines of business or countries.
Leadership & Teamwork
· Clearly communicates Threat Mitigation strategy to meet business needs.
· Provides support at a regional level to the FCTM sub-function.
· Contribute to communication across regional FCR and the business to all key stakeholders in relation to Investigation matters.
Operational Effectiveness & Control
· Adhere to the framework, policies, procedures, and controls for the effective identification and mitigation of the specific financial crime threats the firm faces.
· Adhere to the FCTM-related elements of the Financial Crime Risk FIMs.
· Work within the resourcing, costs, and spend limitations of the function.
· Global and Regional FCR is going through a period of rapid and deep change both internally and externally. Internally we are restructuring the Group's footprint, ensuring that these businesses are run consistently and globally. Working within a large FCR sub-function in such an environment is challenging by itself. However, there are additional challenges from internal restructuring of our business, major cost reviews and implementation of efficiency programmes. The immense amount of change internally and externally calls for the job holder to be alert and adaptable to:
· developing requirements, whilst also delivering challenging targets;
· managing the demands of multiple diverse aspects of the role;
· maintaining a global perspective, but with particular consideration of regional distributions (staff, budgets, resources, operations) and the impact of these, and ensuring a proportionate balance in each region;
· managing a uniform approach to operations, in view of disparate operating procedures already in operation (within the organization and within departments) and the unique issues, requirements and problems associated with each.
· The jobholder is required to work within the Complex Investigation sub-function within FCTM and establish the policies and procedures of the Group in managing these risks. This can involve dealing with major issues for which there is no clear cut solution whilst still being able to provide judgment and clear direction. Where items of major consequence are involved, reference is made to Senior Investigators or the Regional Head of Complex Investigations, FCTM. The nature of the role requires close working contact with senior executives across FCR.
· This is a new position and function that the jobholder will be expected to further define and embed.
Management of Risk
· The jobholder will continually reassess the operational risks associated with the role and inherent in the business, taking account of changing financial crimes threats, geopolitical, economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new technology. Monitor in accordance with the Principal Accountabilities set out above.
· The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organization.
Observation of Internal Controls
· Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.
· Jobholder is an ‘insider' for dealing purposes and subject to strict controls and confidentiality.
· The jobholder's responsibilities cover all of the Group's FCTM operations
Ideal candidate profile
· Experience working within a regulatory, investigative, or financial intelligence agency, or as a compliance manager within a global firm, in the financial services industry.
· Experience in mitigating the harms associated with the threat of financial crime at a strategic level
· Understanding of the current regulatory environment and expectations, relevant regulations, codes, and HSBC Group Standards, as well as their underlying purpose to mitigate risk to the financial system and provide information useful for the public sector to provide law enforcement and security.
· A strategic thinker.
· Excellent communication and inter-personal skills, with experience of dealing with executives at all levels.
· Ability to develop efficient and effective solutions to complex global issues.