Country Compliance Officer (CCO)

Job Title: Country Compliance Officer (CCO)
Division: International Compliance Division (ICD)
Group:Compliance Group
Direct Reporting: ICD Head, Head Office
Administrative Reporting: GM/Country Manager

Position Summary:
The Country Compliance Officer will be responsible to carry out all functions as required under the Global Compliance Policy and local regulations as applicable to Compliance Officers. Compliance Officers will not be assigned any other tasks which may create a conflict of interest.

Duties and Responsibilities:
Liaison with the regulator(s) and Auditors
• Reponsible for being the main point of contact with local regulators and the bank, including during examinations.

Policies & Procedures Review
• Responsible for reviewing and preparing all local policies (where required) for HO approval at least 3 months before expiry date.
• Responsible for preparing procedures for local or global policies related to regulatory compliance, AML (including all financial crimes) and Sanctions compliance or updating/reviewing existing procedures and submitting them for HO review at least 60 days prior to their expiry date,
• Maintain MIS of Policies, Procedures, Manuals and Product Program of the branch

Regulatory Compliance
• Responsible for timely dissemination of pertinent regulatory updates to the Branch Management and ensuring amendments to related Compliance requirements are documented and implemented by the deadline.
• Conduct routine follow-ups for the progress on development of controls and implementation of the updates.
• Report gaps and delays to the relevant branch committee(s)

Advisory
• Provide guidance/advisory to branch management and / or interpretation of regulations, applicable laws and other Compliance matters

Compliance Testing
• Test processes and procedures on a risk basis to identify gaps
• Report gaps to the relevant stakeholders and monitor corrective action plans/deadlines
• Develop the branch’s Internal Risk Assessment Report (IRAR)

Compliance & AML / CFT Training
• Ensure Compliance-related training plan is developed/impared to all staff per the schedule
• Resonsible for arranging/providing employee training in AML/CFT/Fraud/Sanctions at least once per year or more frequently

Regulatory Reporting
• Ensure Annual FATCA & CRS Reporting, as applicable, is prepare and file on time
• Ensure timely submission of compliance related data/returns to regulator, where applicable

Compliance Committee of Management (CCM)
• Ensure branch CCM takes place per its TORs
• Track open matters till closure
• Prepare minutes of CCM meetings in a timely manner
•Develop/implement/update the Branch Compliance program

HO Compliance Group Oversight
• Responsible for informing HO Compliance on notices of upcoming regulatory inspections/ examinations, meetings with regulators/law enforcement agencies, penalties levied and other high-risk gaps
• Timely submit all HO Compliance Reports and respond to all queries in a timely manner
• Responsible for reporting compliance breaches in regulatory inspections / examinations and Internal Control reviews to HO
• Responsible for preparing six monthly reports for the Management and the Board covering compliance risk and regulatory gaps
• Establish a professional, cordial and efficient working relationship with all key personnel of the branch and HO
• Responsible for reporting unmitigatable conflicts between Compliance requirements of home and host countries to HO

Name Screening
- Perform name screening in line with the established procedures and local requirements
- Perform timely update of all manual lists and/or database-systems.
- Ensure updates to negative lists are captured by the bank’s systems in a timely manner and are accurate

Transaction Monitoring & SAR/STR Reporting
- Perform test-checks / review of transactions on a regular basis to ensure NBP is adhering to prescribed regulations and internal practices
- Revise and update the SAR/STR reporting process that will detail the criteria and processes employed to identify, investigate and report unusual and suspicious activity for further investigation and reporting
- Investigate all suspicious transactions reported by staff
- Report suspicious transactions to regulator, as required

Customer Risk Asessment
Conduct periodic risk assessment reviews of new and existing branch customers per the frequency defined for each risk category

KYC / CDD
- Check that all account opening requirements are completed as per bank's policy and local regulations.
- Ensure that proper KYC and CDD are conducted to establish customer profile, including source of income and that name screening against negative lists is performed effectively.

Determine the resources
- Determine the resources required for Compliance Function to carry out all its roles and responsibilities professionally and of desired quality.

Fraud Investigation
- Oversee fraud investigations involving customer accounts and recovery of funds, and coordinating investigations with external investigation and enforcement officials.

Local Requirements
- Member of Management Committee
- C-BCP Team leader of Administration Team
- Supervising the Compliance of Osaka branch