مدير أول لمكافحة غسل الأموال / تمويل الإرهاب ونائب مسؤول الامتثال لمكافحة غسل الأموال Commercial Bank of Dubai

Job Purpose

The role holder is responsible for managing the Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) function as well as providing subject matter expertise to senior management and business units.

The role holder is appointed as the Bank s DMLRO and shall determine whether the escalated AML alerts and suspicious activity need to be reported to the UAE Central Bank's Financial Intelligence Unit (FIU). The role holder will also act as the main contact point for the UAE Central Bank FIU.

Principle Accountabilities

• Oversee the AML/ CFT risk for CBD, owning the AML/ CFT Policy and ensuring compliance with all CBUAE
• regulations, guidance and notices.
• As the Bank s DMLRO, the role holder will have delegated authority to sign and report Suspicious
• Transaction Reports (STRs) to the UAE Central Bank's Financial Intelligence Unit (FIU).
• Review the escalated alerts or suspicions transactions and determine whether they need to be reported to the UAE Central Bank's FIU.
• Manage the received responses or mandated actions from the UAE Central Bank's Financial Intelligence Unit (FIU) on the STRs submitted and support the Head of Compliance with regulatory correspondence.
• Day-to-day management of the Bank s transaction monitoring system to ensure effectiveness, track AML alerts, queues or backlogs and provide the Bank s senior management with an update on the operations and effectiveness of the AML/CFT and Sanctions function.
• Oversee the investigations of the more complex investigations which may originate from Senior Management, the UAE Central Bank, the Police, Whistleblowing or from data analytics.
• Conduct periodic assessments of the Bank s transaction monitoring system to ensure its optimization (i.e. fit-for-purpose), including threshold reviews, segmentation analysis as well as scenario performance analysis.
• Manage the list of scenarios from which the system will trigger alerts to ensure that the rationale behind each rule and the governance in place around the modification of parameters is well documented and mapped against the identified inherent risks.
• Run the Transaction Monitoring Oversight Committee, prepare proposals and act as Secretariat.
• The role holder will have the rights in the AML transaction monitoring system to modify parameters and scenarios with the approval of the Head of Compliance. Any change should be properly documented in order to track modifications, record approvals and capture the corresponding rationale/logic for implementation.
• Provide advice and guidance to the AML team and business areas on AML/CFT related issues.
• Provide updates to the wider AML/CFT team on current events or regulatory changes.
• Own the AML/CFT related policies and procedures remain updated and communicated as required to all stakeholders. The Deputy MLRO is responsible for supporting the MLRO in regularly reviewing and updating policies and procedures to ensure they remain effective in detecting and preventing money laundering and terrorist financing.
• Develop and recommend controls for the identified control weaknesses or potential gaps in AML/CFT related policies and procedures.
• Support the team by reviewing suspicious cases when the volume is higher than the average or when there are staffing constraints that would limit the team s capacity.
• Provide guidance to the AML/CFT Assistant Managers, Senior Officers and Officers on their investigations.
• Define and supervise the Quality Assurance process to review closed alerts and cases on a sample basis.
• Issue client exit requests for financial crime reasons and engage with the Business to further review the escalated cases. Supervise customer exits for financial crime reasons to ensure all mandated exists are being actioned as per the Bank s internal procedures.
• Log and escalate all AML/CFT breaches or potential breaches.
• Review AML/CFT related training materials (i.e. e-learnings and face-to-face) and participate in the delivery of face-to-face trainings.
• Manage the available resources efficiently and prioritize system enhancement/up-grades