Senior Staffing Specialist at Pylon Management Consulting
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Director - Trade Surveillance/Market Abuse - BFSI (12-16 yrs)
- The Director, Fraud Risk for Financial Markets and Treasury Markets is a permanent role that requires strong business acumen and deep knowledge and experience in the Fraud Risk field, particularly with expertise and experience in Institutional Financial Markets, and Unauthorized or Rogue Trading. Internal Fraud refers to frauds committed by staff, contractors, and colleagues within the Bank. This role will provide oversight and challenge for internal fraud for all businesses and functions.
- The successful candidate will have a strong understanding of operating in a second line capacity within a CFCC Advisory and Fraud risk management organisation covering Financial Markets, and can respond flexibly and collaboratively to evolving business, regulatory and threat requirements.
- The role reports directly to the CFCC Advisory Head, FCC Strategy and Risk Management for Financial Markets (FM) and Treasury Markets (TM).
- This role will work closely with both the FM / TM Businesses and related functions, as well as the Fraud Risk organization and other stakeholders to address Rogue Trading Risk primarily, and also Fraud Risk more generally as a financial crime risk sub-type for the Bank (with special focus on Unauthorized or Rogue Trading) and support its integration into the Bank's overall Enterprise Risk Management strategy.
- The role will provide oversight and challenge of Fraud risk management and control effectiveness as a risk partner to Businesses and Functions as defined in the Bank's Operational Risk and Enterprise Risk Management Framework and under delegation from the Global Head, Fraud Risk Management.
- The primary purpose of this position is to ensure that the management of Rogue Trading Fraud risk is operating effectively and efficiently.
- The role will support both the CFCC Advisory Head of FCC Strategy and Risk Management for FM and TM, and the Global Head, Fraud Risk Management in their role as the Bank's executive accountable for Fraud risk.
- The successful candidate will work closely with other control functions like Human Resources, Finance, Middle and Back Offices, Technology, Physical Security, Business and Country COOs, CISO, and Operational Risk Officers, as well as other key stakeholders to drive requirements and help set priorities for Fraud risk strategy and investment based on acceptable risk tolerance by considering the evolving threat and regulatory landscape, policies and standards, and technology infrastructure.
The major functional activities that this role will lead and manage are:
Risk Framework Owner Responsibilities:
- Assist the CFCC Advisory Head, FCC Strategy and Risk Management for FM&TM to carry out the delegation of authority from the Global Head, Fraud Risk Management through establishing a robust Rogue Trading Control Framework through engagement with Functions (Human Resources, Finance, Risk, Property
- Supply Chain Management, CFCC, ITO, etc) and Businesses (Retail Bank, Commercial, Corporate and Institutional Banking, Private and Wealth management)
- Overseeing and challenging 1st line Fraud risk and control proposals and risk-taking activities
- Intervening in 1st line activities if they are not in line with existing or adjusted Risk Appetite
- Monitoring of Fraud risks and associated remediation plans across Businesses and Functions
- Assuring the 1st line implements controls to comply with applicable laws and regulations as defined by the Fraud Risk Policy team and escalate significant regulatory non-compliance matters
- Promoting a healthy Fraud risk culture and good conduct.
Policy and Standards, Implementation and Assurance:
- Establish and Review Financial Crime Risk Type Framework and Fraud Risk Type Framework
- Set and maintain Policy and Standards
- Implementation Policy and Standards
- Monitor regulatory, internal and external environment and notify Policy Owner to continuously enhance Policy and Standards
Training and Awareness, Communication:
- Inputs and Approval for Fraud training and awareness, including eLearning, Fraud Risk Professionals Programme and Rewards for target audience (Staff, 1st Line, Practioners, Senior Management, Client)
Fraud Risk Strategy and Program Co-ordination
- Review fraud risk and threat landscape
Group Fraud Risk Assessment
- Input and Approval of Annual Portfolio and Enterprise level Fraud Risk Assessment (aka Group Risk Assessment)
Operational and Fraud Risk Identification and Assessment
- Challenge and advise on First Line of Defence's (Process Owners) proposals for risk control design standards, thresholds
- Provide Fraud specialist oversight and challenge (Gross Risk Assessment, Residual Risk Assessment), aligned to ORF RFO responsibilities
- Review / challenge Fraud risk remediation plans set by First Line of Defence to mitigate breaches / issues, including risk acceptance
- Recommend controls, thresholds, standards, and Residual Risk levels to 2nd line Country and Group Risk Framework Owners for acceptance
Fraud Technology (Architecture and Solution Design):
- Provide inputs to Tools and Product capability to enable Surveillance and Monitoring
Fraud Scenario Development, Surveillance and Analytics
- Oversight and Challenge of Fraud Scenarios, deployed into Surveillance and Analytics environment ensuring effectiveness (Risk and Loss), efficiency (Cost of Operations) and experience (Customer)
- Provide inputs and support Fraud Response by working with Collective Intelligence and Command Centre (CnC) and other Risk Owners (Cyber Security, Financial Crime, Conduct) where relevant.
- Oversight and Challenge over root cause analysis, process remediation and socialization of lessons learned
- Identify thematic issues and improve control design and improve controls through regular reviews of external events, audit findings, SIS reports and other relevant information
- Establish ongoing engagement / collaboration with other investigation community, assist and support investigation
People and Talent:
- Lead through example and build the appropriate culture and values.
- Set appropriate tone and expectations from team and work in collaboration with risk and control partners.
- Ensure the provision of ongoing training and development of people, and ensure that holders of all critical functions are suitably skilled and qualified for their roles ensuring that they have effective supervision in place to mitigate any risks.
- Employ, engage and retain high quality people, with succession planning for critical roles.
- Responsibility to review team structure / capacity plans.
- Define an organization structure aligned and scaled to the risk control needs of the Functions.
- Set and monitor job descriptions and objectives for direct reports and provide feedback and rewards in line with their performance against those responsibilities and objectives.
- Uphold and reinforce the independence of the second line Fraud Risk function.
- Deliver the defined aspects of the CFCC Advisory and Fraud Risk role to support the Group's Fraud risk management approach and objectives.
- Ensure that the Fraud risk role is managed in accordance with the defined Fraud Risk Framework and associated Policy and Standards; and that issues are identified, escalated, and addressed as appropriate.
- Manage the Fraud Risk team professionally and efficiently, closely tracking deliverables and commitments.
- Establish strong ties into the relevant governance, risk and control committees to ensure adequate monitoring, tracking and governance of Fraud risk.
- Drive integration of Rogue Trading Fraud Risk Framework and associated Policy and Standards into functions and utilise for the ongoing governance process established within the Bank.
Regulatory and Business Conduct:
- Display exemplary conduct and live by the Group's Values and Code of Conduct.
- Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.
- Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.
- Functions Heads (HR, Finance, Property, ITO, etc)
- Business and Function COOs
- Business and Function Information Security Officers
- Business and Function Operational Risk Officers
- Business and Function Compliance Officers
- Anti-Bribery and Corruption Officers
- Head of Shared Investigation Services
- Establish strong relationships with identified stakeholders and understand their strategic goals, to ensure Fraud risk alignment.
- Articulate the value of Fraud risk controls and their financial impact, regulatory and reputational cost to functions.
- Prepare, present and challenge in a 2nd line capacity at relevant risk committees, steering groups, and cross-functional opportunities.
- Perform Delegation of Authority (DoA) responsibilities for Fraud Risk as defined for the functions.
- Measure efficient and effective management of Fraud risk for the functions.
- Validate the accuracy of KRI's and KCI's and other risk ratings, as well as process designs, to meet policy requirements.
- Ensure that Process Owners are escalating risk, control, and process deficiencies appropriately in accordance with the relevant risk frameworks.
- Build trusted working relationships with other functional heads, risk and compliance counterparts, and function unit stakeholders.
- Utilise appropriate risk management tool(s) to manage, track and monitor Fraud risks across the functions.
- Maintain sufficient and appropriate evidence of work performed for review by Group Internal Audit and others.
- Monitor, assess and advise functions on acceptable risk tolerances based on policy and control environment and the evolving regulatory and threat landscape.
Our Ideal Candidate:
- Graduate degree (Master's) and / or professional certifications have an advantage (e.g., CISA, CFE, CPA).
- Overall working experience of >12 years, with relevant role experience of >5 years
- Proven experience in a Financial Markets control or 2nd line function and on a secondary basis, Fraud risk management, senior governance and policy, Fraud investigation, or audit role, preferably in the Fraud risk field.
- Experience working in or with the financial services industry with keen understanding of business, functions, and its operational environments, particularly with Financial Markets businesses and Rogue Trading controls.
- Strong leadership, negotiation and collaboration skills, and ability to work effectively in a complex multicultural and multi-time zone organization.
- Thorough understanding of Banking business and functions processes, risks, threats, and internal controls.
- Ability to collect and analyse data, establish facts, and make recommendations in written and oral form.
- Ability to liaise with all parts of the Bank, including risk and functions stakeholders.
- Experience in leading a geographically dispersed organization.
- Excellent oral, written and communication skills.
- Strong analytical and program management skills.
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