Manager Financial Crimes Compliance

KYC/AML/CFT Policy & Procedures and Risk Assessments

• Development, implementation and updation of Bank’s AML/KYC/CFT/CPF policy and procedures.
• Regularly review the Bank’s policy and procedures in the light of AML Act, ATA Act, UNSC Sanction Regime, SBP Regulations, FATF recommendations, Risk Assessment reports, and international best practices and make recommendation for necessary changes.
• Updation of Bank’s risk assessment regarding KYC / AML / CFT / CPF / TFS as per regulatory instructions and national risk assessments.
• Periodical assessment of ML/TF / PF /Transnational risk posed to the Bank and effective implementation of controls commensurate with the level of ML/TF/PF / Transnational risk posed from different channels.

Compliance of UNSC and Targeted Financial Sanctions Regime

• Manage CFT Desk and ensure compliance of Targeted Financial Sanction’s Regime, Sanction’s screening activity, freezing / de-freezing actions under UNSC Sanction Regime & Anti-Terrorism Act 1997, global watch lists and instructions received from other law enforcement agencies (LEAs).
• Maintenance and updation of screening parameters and scenarios in FCM as per ML / TF risk posed to Bank.

Transaction Monitoring & Alert Management

• Ensure efficient transaction monitoring over customer’s account as per SBP’s guidelines and Bank’s policy and procedures.
• Administration & management of Transaction monitoring Rules / scenarios as per ML / TF risk posed to Bank.
• Ensure review of Transaction Monitoring Alerts escalated by AML Analyst/ CFT officer for closure or possible reporting of STR to FMU.
• Management Reporting.

 KYC/CDD Reviews and CTR & STR Reporting

• Monitor and ensure compliance over KYC / CDD related activities as per Bank’s policy & procedures.
• Monitor and ensure timely and accurate reporting, record keeping of Currency & Suspicious Transactions (on ML / TF / PF / TFS / Transnational Risk or any illegal activity) to Financial Monitoring Unit (FMU) as per defined procedures and guidelines.
• Monitor and ensure timely response to queries by FMU regarding submitted CTR/ \STR or any other financial intelligence.
• Manage the user administration for go AML.

 KYC/AML/CFT Training

• Develop the KYC / AML / CFT / CPF / TFS related training plan of Bank complying all the regulatory requirements and Bank’s policy.
• Develop, and update the KYC / AML / CFT / CPF / TFS training modules as per regulatory requirement, best practices and risk assessments conducted by Bank or external authorities.
• Planning, executing and delivering compliance trainings for all staff of KMBL covering all significant areas of KYC/AML as per approved training plan.

 Liaison with Law Enforcement Agencies & Authorities

• Monitor and ensure the efficient handling, recording and responding to queries received from LEAs.
• Monitor and ensure the compliance of Freezing/de-freezing actions as per instructions received from LEAs regarding customer’s accounts.

 FATCA & CRS Compliance

• Develop and maintain a compliance program that includes policies, procedures and processes that sufficiently comply with all of FATCA rules and regulations.
• Monitoring of FATCA & CRS regulatory environment and relevant updating of legal documentation process.
• Updating KMBL’s status on IRS and Periodic Reporting under FATCA.
• Development & implement CRS related procedures.
• Identification & record keeping of Reportable Accounts under CRS.
• Ensure periodic reporting under CRS / FATCA and liaison with regulatory authority regarding their compliance.

 Whistle Blowing & Additional Tasks

• Handling of the receipt, retention, and treatment of alleged malpractices / misconduct. 
• Assist in the process of investigations internally or referred to an independent investigator and record keeping of relevant documents.
• Prepare weekly, bi-weekly, monthly and quarterly reports for CCO/BAC or Bank’s Management.
• Assisting in any other relevant tasks/Assignment by Management.