Deputy Head of Financial Crime Compliance & MLRO

Role       : Deputy Head of Financial Crime Compliance & MLRO
Location : Abu Dhabi

Role Purpose:

The MLRO & Deputy Head of FCC is responsible for establishing and overseeing an effective and sustainable Anti Money Laundering ("AML") program, inclusive of people, processes, systems, and controls across the ADIB Group. The MLRO & Deputy Head of FCC is required to ensure that all business activities of ADIB Group are in accordance with applicable FCC laws and regulations and international best practices, as well as requirements of the ADIB's FCC policies and procedures. The MLRO & Deputy Head of FCC is responsible for leading and managing all AML unit  and areas, including AML/CTF (including predicate offences, e.g., fraud, human trafficking, etc.), , Anti-Bribery and Corruption.
    
Key Accountabilities of the role      

Strategic Contribution 

• Ensure effective implementation and oversight of the Group's Compliance strategy within the AML team's remit to ensure vertical alignment and horizontal integration with other interfacing departmental strategies.

People Management 

• Set and approve the core competencies of AML roles. 
• Develop a capable AML team with good technical competence and work with Unit Head of Sanctions and Unit Head of CDD and ODD to ensure that the FCC function is appropriately staffed.
• Provide guidance and coaching to direct reports.
• Act as a role model to direct and indirect reports to drive adherence to organizational values and ethics and foster a value-driven culture within the Group.

Budgeting and Financial Planning 

• Review and recommend the AML team's budget to Group Head of Compliance and monitor adherence to budget, while ensuring all sectional activities are conducted in line with the approved guidelines. 

Policies and Processes 

• Ensure that ADIB Group have complete and up to date FCC governance documents (e.g., AML policies, procedures, risk assessment methodologies) that allow the ADIB Group to comply with all local regulations and international best practices. 
• Contribute as a thought-leader to evaluate and refine FCC and AML policies, procedures, and processes and implement best practices at a Group level.
• Identify opportunities for continuous and sustainable improvement of FCC related systems, processes, and practices.

Financial Crime Compliance 

• Establish and lead the AML function within the GCD.
• Build the Group FCC framework based on best international practices and in line with local laws and regulations. 
• Oversee the Group-wide implementation of FCC controls as required by the Group FCC framework as a co-responsibility with Unit Head of Sanctions and Unit Head of CDD and ODD
• Ensure that ADIB Group is fully aware of and complies with all relevant FCC regulations and international best practices and assess its impact on ADIB. 
• Oversee the monitoring activities at the Compliance Operations Center (COC) and ensure constant feedback and governance.
• Review MIs pertaining to monitoring operations at COC, COEand identify anomalies and trends to manage the risk and efficiency 
• Ensure right-sizing of the teams at COC to ensure SLAs are met while managing the budget efficiently as well 
• Ensure process and resource deficiencies are identified and fixed / replacements happen on timely basis 
• Attend industry or other external events relating to FCC as appropriate to keep abreast of recent developments and best practices. 
• Establish and manage FCC, AML related risk models, as a co-responsibility with Unit Head of Sanctions and Unit Head of CDD and ODD
• Ensure that violations of AML policies and procedures are appropriately identified and escalated. 
• Provide SME advice and guidance to Business units on, but not limited to, AML/CTF, ABAC, and recommend measures to achieve compliance with all FCC related policies, procedures, laws, rules and regulations. 
• Provide inputs on FCC training contents and ensure the complete roll-out of all FCC mandatory training in accordance with the annual compliance training plan. 
• Take a leading role in the delivery of face-to-face FCC training, whenever required. 
• Assume the roles and responsibilities of ADIB's Money Laundering Reporting Officer (MLRO) as registered with the CBUAE.
• Actively build relationships and engage AML regulators with jurisdictions over ADIB. 
• Ensure that ADIB has a clear, efficient, and effective process for staff to report suspicious transactions to Compliance. 
• Oversee the production of all internal and external STRs.
• Manage Compliance's relationships with the ADIB's Correspondent Banks, including but not limited to, managing all enquiries and signing AML / CTF / Sanctions questionnaires. 
• Provide tactical and strategic solutions to FCC issues.
• Represent ADIB to manage FCC related regulatory inspections and advise Regulatory Affairs function to co-ordinate all FCC specific regulatory communications, including examinations, inquiries, and enforcement requests, where required and appropriate. 
• Ensure there is a framework for compliance and required reporting to regulators for AML predicate offences including liaising with Fraud Risk Management and Fraud investigations. 
• Manage the FCC Technology team and oversee the implementation and maintenance of all FCC related IT systems and associated projects. 
• Oversee implementation of internal and external audit recommendations for findings against the FCC function, as a co-responsibility with Unit Head of Sanctions and Unit Head of CDD and ODD 
• Act as an SME to support and assist the Compliance Monitoring, Assurance and Testing (CMAT) team in the development of AML related CMAT plans. Support the CMAT team in the execution of FCC assessments, tests, and special reviews.
• Represent FCC in regular management meetings as well as support Group Head of Compliance in Senior Management meetings.

Reporting

• Ensure that the Group Board and Management Committees, Group Head of Compliance, and the Group's Senior Management are well informed of critical AML clans, initiatives, and issues/violations.
• Review and sign-off on AML related MI to the Committee and Senior Management meetings. 
• Review results of AML investigations and present findings to the Group Head of Compliance. 
• Review all applicable reports before submission to regulatory/law enforcement authorities in UAE including: 

           o Suspicious Transactions/Activities Report 

           o MLRO Report

Relationships across the 3LOD 

• Liaise with Group Audit and Risk Management departments on FCC related matters as a co-responsibility with Unit Head of Sanctions and Unit Head of CDD and ODD

• Engage with various Business units to deliver a robust and integrated FCC program across the Group.

Specialist Skills / Technical Knowledge Required for this role:

• Master's Degree in Science, Finance, Business, or a related subject. ACAMS certification or equivalent. 

• 15+ years of FCC experience gained at a top tier international bank, which includes 8-10 years of experience managing large and complex AML / CTF / Sanctions teams. 

• Experience in advising or working in a Compliance function with a focus on delivering a robust FCC program. 

• Strong track record in dealing and managing regulators and other stakeholders. 

• Strong interpersonal skills with the ability to communicate with impact, build healthy professional connections, influence outcomes, simplify complex topics into actionable recommendations for decision-making. 

• Exceptional knowledge of all aspects of FCC and relevant regulatory requirements for AML/CTF, Sanctions, KYC/CDD, and ABAC prevalent in the UAE and across ADI B's international jurisdictions such as Qatar. Iraq, Sudan.

• Exemplary knowledge and understanding of international and cross border rules and regulations (such as OFAC, UN, and EU sanctions regimes, FATCA, FATF, and BIS).

• Ability to perform innovative thinking to solve complex problems with no established precedence while balancing risk, speed, and accuracy.