Senior Manager, Financial Crime Compliance at CRDB Bank

JOB REPORTING TO : Head of Compliance and Governance


The Purpose of the job is to support and define the bank’s AML & Sanctions Monitoring strategy and goals across the bank, guiding the program. To ensure the bank has relevant, up-to-date, and adequate policies, procedures, processes, and strong controls to support the management of Financial Crime Compliance (FCC) Risks; FCC risks include Money Laundering, Terrorism Financing, Sanctions, and Anti-Bribery & Corruptions Risks. Oversee the first line of defense in implementing the requisite AML & Sanctions controls, processes, and systems to comply with applicable laws, rules, and regulations, as well as frameworks, policies, and procedures.


FCC Program Management

Champion effective implementation of methods to identify, assess, and mitigate AML/CFT/CPF, and Sanction risks across the Group.
Provide oversight and support to the bank’s Compliance Risk Infrastructure that monitors Suspicious Activity, AML, and Sanctions violations.
Harmonize to the greatest extent possible AML & Sanctions Compliance policies, procedures, and Risk Assessments across the Enterprise.
Design and support implementation of Enterprise KYC/CDD programs consistent with AML regulatory requirements and the bank’s specific risk profile.
Conduct examinations and assessments of the bank’s AML/CPF/CFT and Sanctions Compliance programs: Develop an annual schedule and continuous process for compliance testing and monitoring activities across all business line functions.
Oversee and ensure the production of timely and effective AML, Sanctions, and Transaction Monitoring-related MIs and other applicable information to the Director of Risk & Compliance, Management Operational Risk Committees, and Board Risk Committee.
Support the design, development, and implementation of strategies, standards, and procedures to support the AML/CFT/CPF Data Governance program while facilitating adherence to the bank’s Enterprise Data Governance framework for data policies, standards, and practices.

Enterprise Risk Assessment & Control:

Provide oversight to the bank’s Compliance Risk Infrastructure: Safeguarding operational and compliance risks governance, policies, and standards are enforced by all lines of businesses and support units.
Participate in Annual Compliance Risk Assessments – play a key role in the assessment through all stages. Provide quarterly risk assessment and updates to the Board and management on the closure of audit issues.
Review new products and services to ensure appropriate consideration of key AML/CFT/CPF and Sanction compliance risks and any necessary mitigating controls.
Implement and coordinate Compliance Risk Management Processes while challenging the First Line of Defence (FLOD) on the effectiveness of controls: Drive finalization of risk category and subcategory framework for Risk and Control Self Assessments, Product Risk Assessments, and Process Level Assessments.
Design and implement Risk Based Alerts Scoring Models: Lead the development and maintenance of the Enterprise AML Transaction Monitoring strategies, including scenario development and rules optimization to support AML and Forensic Risk Identifications.
Design and Implement vendor’s due Diligence Framework: Develop vendor’s risk categorizations and implement Due Diligence commensurate with risk levels.
Consistent with AML regulations and policy recommend De-Risking initiatives to management based on increased customers’ or Product Risks Profile against established bank’s AML risk appetite.
Design risk-based Financial Crime Compliance Training and ensure training requirements are implemented across the group by staff.
Perform other duties as assigned by the Head of Compliance & Governance.


Degree from a reputable University preferably in Law, Economics, Finance, Risk Management, or a related discipline.
Holder of ACAMS Certifications or intention to be certified within six months of employment.
7 + years of experience in the banking industry or regulatory environment; at least 5 years in AML/CFT and OFAC/ Economic Sanctions compliance.
Experience in dealing with regulatory matters and confident interaction with Management, Board, and Regulators.
Significant experience in Risk and Operations Management together with business management, from a frontline role in Commercial Banking
Ability to identify, escalate and communicate issues to management in an effective and succinct manner
Strong knowledge of AML laws & Sanctions regulations and their application.
Excellent project management and organizational skills and capability to handle multiple projects at one time
Advanced knowledge of Excel, Access, Word, PowerPoint, and Projects.
Excellent written, and verbal communication, and analytical skills
High level of moral and Ethical standards Generally applicable to the bank


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