Role Summary

We are seeking an experienced Financial Crime Compliance professional to lead the Bank's AML Policy function. The successful candidate will provide subject-matter leadership across regulatory change, policy and framework development, enterprise-wide and customer risk assessments, new product reviews, AML systems governance and transaction monitoring oversight. This role works closely with business, operations, technology and control functions, delivering updates and recommendations to Senior Management and relevant governance committees.

1. Lead the implementation of new or revised requirements arising from MAS Notices, Guidelines, Circulars and Information Papers, as well as Head Office requirements and internal policies relating to anti-money laundering, countering the financing of terrorism and proliferation financing (AML/CFT/PF), and targeted financial sanctions (TFS).
2. Monitor regulatory developments, assess their impact on the Bank’s AML/CFT/PF framework, and conduct gap analyses against existing policies, procedures, systems and controls.
3. Develop implementation plans, coordinate cross-functional delivery, track progress and report key updates to Senior Management and governance committees.

1. Provide expert, practical and risk-based advice to Business Units and Support Functions on AML/CFT/PF, sanctions and related regulatory matters.
2. Advise on customer due diligence, enhanced due diligence, beneficial ownership, source of wealth and source of funds, higher-risk customers and complex ownership structures.
3. Support regulatory inspections, internal and external audits, and Head Office reviews.

1. Develop, review and enhance AML/CFT/PF policies, standards, procedures and guidance, ensuring alignment with MAS Notice 626, applicable MAS Guidelines, FATF Recommendations and Head Office requirements.
2. Drive continuous improvement of the Bank’s AML/CFT/PF framework, controls and governance arrangements.
3. Serve as Secretary to the Bank’s AML/CFT/PF Committee, including preparing agendas, papers and minutes, tracking action items and reporting implementation progress.

1. Lead and coordinate the Bank’s Enterprise-Wide ML/TF/PF Risk Assessment (EWRA), covering inherent and residual risks across customers, products, services, transactions, delivery channels and geographic exposure.
2. Evaluate the effectiveness of mitigating controls, recommend enhancements, and present EWRA results and recommendations to Senior Management and relevant governance committees.
3. Lead the development and periodic enhancement of the Customer Risk Assessment (CRA) methodology and Customer Risk Rating framework, including risk factors, scoring methodologies, classifications, validation and governance.

1. Review new products, services, delivery channels and strategic initiatives from an AML/CFT/PF and sanctions perspective.
2. Conduct risk assessments, recommend appropriate mitigating controls and participate in New Product Approval Committees where required.

1. Oversee governance relating to AML systems, including customer risk assessment, name screening and transaction monitoring systems, as well as user access governance for AML-related systems.
2. Participate in AML system implementation and enhancement projects, providing compliance input on proposed transaction monitoring scenarios, threshold tuning and system changes.
3. Partner with Transaction Monitoring, Operations and Technology teams to ensure monitoring controls remain aligned with regulatory expectations, emerging typologies and the Bank’s ML/TF/PF risk profile.
4. Participate in governance forums and effectiveness reviews relating to the Transaction Monitoring programme.

1. Degree in Law, Finance, Business, Accounting or a related discipline.
2. At least 10 years of experience in AML/CFT, Financial Crime Compliance or Regulatory Compliance within the banking industry.
3. At least three years of experience leading teams or major regulatory projects.
4. Strong track record in implementing MAS AML/CFT requirements and regulatory change initiatives.
5. Demonstrated experience leading Enterprise-Wide Risk Assessments and developing or enhancing Customer Risk Assessment methodologies.
6. Experience reviewing new products from an AML/CFT/PF perspective and supporting AML systems enhancement initiatives.
7. Sound understanding of Transaction Monitoring governance and AML technology.
8. ACAMS, ICA or an equivalent professional certification would be an advantage.

1. MAS Notice 626 and related AML/CFT Guidelines
2. AML/CFT/PF risk management, customer due diligence and Customer Risk Assessment
3. Enterprise-Wide Risk Assessment
4. Sanctions and targeted financial sanctions
5. AML systems, technology and Transaction Monitoring governance
6. FATF Recommendations

1. Excellent command of written and spoken English.
2. Proficiency in written and spoken Mandarin is required, as the role involves reviewing Head Office policies and documents prepared in Chinese, drafting bilingual correspondence where required, and liaising regularly with Chinese-speaking stakeholders.