Financial Crime Analyst - Sanctions (AVP)

Company:  Sumitomo Mitsui Banking Corporation – SMBC Group
Location: London
Closing Date: 02/11/2024
Hours: Full Time
Type: Permanent
Job Requirements / Description
Purpose of Job Working within the Financial Crime Middle Office on behalf of all EMEA offices, the Controls Analyst will assist with the testing and configuration of technology updates, system upgrades, new system implementations and regulatory driven changes, that will impact workflows, or systems use. This includes extensive testing on tuning and rule changes, before providing results for sign off by stakeholders across EMEA Maintain all Sanctions Screening Governance documentation. Assist with the testing and configuration of technology updates, system upgrades, and new system implementations within the Transaction Control areas. This includes extensive testing of tuning and rule changes, before providing results for sign off by stakeholders across EMEA They will complete daily reconciliations to ensure that the sanctions list’s, which transactions, entities and individuals are screened against, are current and accurate. Background The Rules and List Management Utility is a newly formed team within OPPD – OAD and has been established to ensure that there is a sustainable, independent BAU capability to proactively manage the tuning of Transaction Control applications thus ensuring that the processes are both effective and efficient in detection. This role is within the first line financial crime team, to ensure that our monitoring / screening systems are working at peak effectiveness and efficiency. Ensure the correct governance is followed for the deployment of rules and exceptions Pre-emptive Data analysis to prevent potential production issues Liaison with technology teams to stay current on Fircosoft platform enhancements/changes. To assist and participate in projects and new initiatives within the Screening / Monitoring programme. The role will need to assist and work closely with all members of RLMU and all areas of the CPD Financial Crime Group across EMEA (MLRO / Sanctions / Forensic), as any changes to system logic will impact the second line oversight and control, they need full transparency on what the change is, the testing results and predicted impacts. The role will assist in ensuring that any downstream applications and reporting, still functions as designed, and that any change has not had any unforeseen impact to any other system or team. As part of data analysis, the role will highlight emerging threats / patterns of behaviour and proactivity target this, to help prevent attempted criminal behaviour. To increase operational efficiency and effectiveness by using financial crime data analytics to tune the systems to reduce false positive and helping bring forward more worthwhile alerts for investigation and ensuring our false positive hits are within industry standards Accountabilities & Responsibilities Support Ad Hoc Tuning Requirements - Ad-Hoc tuning activity is centered on the latest Sanctions Hit Data, incorporating MI, KPIs, and user feedback. Through this iterative process, the aim is to refine the effectiveness of the sanction screening mechanism. By analysing the most recent data and user input, potential areas for improvement are identified. This entails assessing whether new rules or exceptions can be implemented to enhance the accuracy of hit identification and reduce false positives. Comprehensive documentation of hits, list IDs, and the feasibility of rule and exception implementation facilitates a detailed evaluation of the tuning exercise's potential benefits. List Completeness - Review of the list origins, designations, keywords and low-quality alias exclusions against the existing agreed matrix. Document and provide the necessary rationale for any revisions and obtain the relevant sign offs. Payment Completeness - Inclusions and Exclusions - This activity involves documenting the rationale for payment exclusions from the payment screening engine (including the relevant sign offs). The process ensures clarity and consistency in identifying which payments are subject to sanctions screening and which are exempt Periodic List Data Review & Optimisation - Systematic examination of existing Sanction lists (internal & external). Through meticulous analysis, any anomalies identified are documented and discussed with the relevant local compliance areas for further comment on appropriateness. Agreed amendments to be documented and initiated in FADE Head Office List Reconciliation - alignment of EMEA grey lists against Head Office records. Look to ensure accuracy in screening, any duplications between these lists should be documented and initiate discussions with the relevant compliance areas to remediate. Rationale to be documented. List Change Performance - Evaluate the impact on hit rates against the latest list file. Track KPIs to start to build a view of the impact regulatory and grey lists have on operations (investigation volumes). Effectiveness Testing - Complete fuzzy and exact match testing against the latest screening configuration files. This will provide the baseline and then benchmark going forwards for screening effectiveness against the latest Sanctions lists. Benchmarking Performance - Evaluate screening KPIs against the agreed benchmarks. Analyse key metrics like hit rates, processing times, effectiveness rates and identify areas for improvement, suggesting system refinements to enhance the screening engine performance. Change Related Standards and Procedures - The activity involves updating and adapting the regulatory standards and internal procedures within EMEA team. This process ensures alignment with evolving regulatory requirements, industry best practices, and Support Reg & Market Related Change & Testing (LCM9) internal policies. Changes may include enhancements to sanctions screening protocols, adjustments to compliance frameworks, and revisions to documentation procedures. Support regulatory and market related changes including impact assessments (i.e. Ongoing Sanctions changes, ISO 20022 MX, decision reapplication enhancements, EMEA configuration testing support for global changes, Enhancements identified from SWIFT STS Testing). React to the need for a Emergency rule to be implemented same day if a Serious spike is caused by list updates Ensure any Manual List updates are feed via RMLU team for oversight and to ensure Data Quality is correct BAU Top Hitters - tuning exercise that involves reviewing the top match-texts to determine if rules and/or exceptions can be introduced to mitigate false positives. Each match-text undergoes analysis to ascertain the feasibility of creating rules or exceptions to suppress erroneous alerts. Essential data such as the number of hits, count of list IDs, and the potential for rule, exception, or both are documented - this meticulous recording provides a comprehensive understanding of the potential advantages of the tuning exercise, aiding in the precise identification and suppression of false positives. Resource File Maintenance – Resource file is updated by ITSD - Ensure any new resource file is tested to ensure its implementation will not cause any unnecessary Spikes in Hit rate. The File contains data used for fuzzy matching based on industry practice (e.g. individual synonyms – Edward, Ed, Edwardo, update of major cities of all countries, country ISO codes, etc) Volume Analysis – Conduct Analysis on the configuration inputs (Updates to Resource File and Lists) to identify any potential spike impact. Report Documentation - Monthly distribution of management information related to Volume Analysis Ad Hoc Tuning Requirements - Ad-Hoc tuning activity linked to upgrades of the Fircosoft Applications and any other internal 3rd party requests. Tuning Calibration - Tuning Calibration in the process of adjusting parameters and algorithms within Fircosoft system to optimise effectiveness and efficiency. Tuning Calibration involves analysing historical data (including historic rules), monitoring model effectiveness, and fine-tuning thresholds and criteria to ensure effective detection of sanctioned entities while minimising false positives. Tuning Calibration enables the sanctions analytics function to adapt to evolving regulatory requirements, changing risk profiles, and emerging patterns in financial transactions, ultimately enhancing the effectiveness of sanctions screening and compliance efforts Education & Qualifications Knowledge and experience of Financial Crime technology/systems/processes - An understanding of the Banks processed and core system and how these interact with the monitoring and sanction systems. A good understanding of core Bank products such as Trade Finance, Loans and SWIFT payments Experience with analytical or database querying software such as SQL and Python along with cloud technology such as AWS and Snowflake The ability to identify wider business impacts or opportunities across key outputs and processes. Ability to work unaided on projects and manage their own time to meet deadlines. The role requires excellent communication skills, both written and verbal Ability to collaborate with all levels of personnel with differing expertise and backgrounds as part of project workstreams. Challenges This is a new role where capability often needs to be built from scratch. The organisation has a culture of long-standing tradition and can be change adverse. This role requires the ability to absorb complex subject matter rapidly and not be afraid to ask questions to ensure clarity and accuracy There is a complex change delivery model involving multiple entities and functions and there will be a need to maintain clear boundaries of this role as discrete from typical project and product management
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Sumitomo Mitsui Banking Corporation – SMBC Group
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