Head of Financial Crime & MLRO
Shawbrook is a specialist UK lending and savings bank founded in 2011 to serve the needs of SMEs and people in the UK with a range of lending and savings products.
We differentiate ourselves by concentrating on markets where our specialist knowledge and personalised approach to underwriting offer us a competitive advantage. This supports attractive stable returns and sustainable growth and benefits businesses and consumers in parts of the market which continue to be poorly served by traditional high street banks. Fundamental to our success is a relationship focus which puts the interests of our customers and business partners at the heart of everything we do, built on a culture which stresses the use of our experience and judgement to make decisions that balance risk, return and customer need.
The MLRO and Head of Financial Crime is responsible for ensuring that Shawbrook is compliant with both internal and external policies and regulations relating to financial crime. The MLRO oversees the development and implementation of a control framework, policies, processes and procedures that facilitate compliance and works with other executives to ensure compliance throughout all divisions within the Bank.
The MLRO is an FCA SMF and acts in the capacity of a senior manager who is allocated the MLRO function – Senior Manager Function 17. The MLRO guides the 2nd line of defence financial crime function and has ultimate responsibility for managing the bank's policies and procedures for countering the risk that the Group might be used to further Financial Crime and fund terrorism. The MLRO is allocated responsibility of reporting to the Board on compliance with financial crime legislation and regulation.
- Formulate financial crime strategy and best practice to support the group in the delivery of its goals.
- Consults with the executive and management to set financial crime policies and oversee the development of procedures designed to achieve compliance with applicable laws and regulations, which are customised to the affected divisions, incorporating regulatory guidance, as appropriate.
- Identify potential areas of compliance risk; develop/implement corrective action plans for resolution of problematic issues and provide general guidance on how to avoid or deal with similar situations in the future.
- Report to management where necessary to ensure that concerns and recommendations are clearly articulated, and appropriate action can be taken as necessary.
- Reports to the chief compliance officer where necessary to facilitate escalation of significant risks to executive management and/or the board/risk committee/audit committee.
- Work closely with general counsel on the identification of new and changes in existing laws, regulations, and industry standards relevant to financial crime and takes a leadership role to ensure the bank remains compliant.
- Works closely with the 1st line of defence divisional risk directors to ensure appropriate delivery of financial crime systems and controls in line with bank policy and risk appetite.
- Act as SME and key contact on financial crime matters including those affecting the development, launch and review of the bank’s products.
- Provide financial crime input into bank-wide projects and initiatives so that new products, business lines, distribution channels and processes are designed compliantly.
- Working closely with the CRO and the enterprise risk director to ensure alignment of the financial crime risk control framework with the enterprise risk management framework.
- Delivers the enterprise risk requirements for the effective oversight of the bank’s financial crime risk.
- Design of 2nd line of defence monitoring programs to provide assurance that financial crime risks have been identified and addressed. Ensuring that risks identified, and controls deployed to mitigate those risks, are consistent with bank’s risk appetite policy and framework.
- Identify emerging financial crime risks (including membership of the regulatory change working group) by closely monitoring regulatory developments and internal and external business initiatives, including due diligence and integration and evaluates the impact of business process changes necessitated by regulatory developments and other events, and consults with and advises management as to necessary business and corporate processes to promote day-to-day financial compliance.
- Maintains coordinated information gathering and communication processes to report or facilitate the CRO's reports on financial crime matters to successive levels of management and board committees.
- Leadership of the financial crime function
- Maintain communication channels within function to inculcate coherence and a team spirit.
- Ensure that staff maintain high standards of professional conduct, ethics, integrity, and control in all their daily operations.
- Set performance goals and key performance indicators, for performance monitoring and quality measurement purposes for the function.
- Recruit, develop and retain talented people/skill sets to ensure appropriate succession plans are in place for function.
EXPERIENCE & QUALIFICATION
- Experience in financial crime discipline is needed
- Managerial experience is needed
- Experience as an MLRO in financial services
- Advanced degree and/or professional designation needed (financial crime)
- Financial crime/regulatory/legal experience in financial services, banking
TECHNICAL/SPECIALIST KNOWLEDGE & SKILLS
- Excellent understanding of the financial crime regulations and risk management skills
- In depth understanding of the financial services sector (deposits/lending)
- Excellent commercial and financial acumen
- Excellent capability in strategic thinking and effective business planning
- Excellent customer and market insight
- Highly analytical
- Well-developed leadership skills (both people and thought).
- Excellent work ethic, energy and personal commitment to results
- Ability to package and present ideas in a persuasive manner
- Ability to prioritise and manage multiple and complex projects simultaneously
- Demonstrates sound business judgment
- Excellent influencing skills and the ability to communicate
This role is an SB1 within Shawbrook’s internal banding structure.