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Director, AML Risk Management
BMO Financial Group
Chicago, IL, United States
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Description
The Director, AML Risk Management oversees the AML and Sanctions Risk management programs for BMO U.S. The Director provides strategy and leadership for AML Advisory teams, Emerging Risks and Complex Customer Support, AML and Sanctions Risk Assessments, Customer Risk Scoring and KYC Subject Matter Expertise. The Director will work closely with the U.S. Chief AML Officer (U.S. CAMLO) and the U.S. AML Leadership team to oversee, measure and report on the risk vs reward equations of BMO U.S.’ customers, products, and services. The Director will provide advice and council as well as effective challenge to the first line of defense AML Officers, i.e., AML Reporting Officers (AMLROs) as they manage AML and Sanctions risks for their line of business. The Director will promote adherence to the established AML Program Framework as well as oversee the development, management and execution of an effective AML program. The Director will oversee efforts to comply with U.S. AML and Sanctions regulations on behalf of the various U.S. lines of business.
The Director will provide subject matter expertise on higher risk types including, but not limited to Money Service Businesses (MSBs), Third Party Payment Processors (TPPPs), Correspondent Banking, Virtual Currency related businesses and Marijuana related businesses. The Director will update the U.S. CAMLO and the U.S. AML Leadership team on new and developing emerging risks and trends in the industry. The Director will also partner very closely with the first and second line teams on managing risks for new products and services.
Working under the direction and context from the U.S. and Enterprise AML Program standards, the Director establishes, develops and maintains an AML risk management program framework that supports the identification, assessment and management of AML and Sanctions risks across the U.S... The Director will work closely with the Enterprise Director of AML Risk Management to ensure consistent standards, processes and controls are established in the U.S. and internationally while respecting local jurisdictional requirements. The Director will maintain a robust system of reporting that facilitates ongoing monitoring of AML risks across all U.S. business units and provides executive management, the U.S. AML organization, and the U.S. Line of Business Heads timely and accurate information on the AML risk profile of the U.S. operations. As such, the Director has the authority to access data and systems required to execute on this mandate and follow up with management with respect to risk mitigation activities.
Ensure BMO’s AML program is managed in an integrated fashion to ensure a collective view of the AML risk-related issues impacting the Bank’s operations. Includes:
• In alignment with the business strategies and within the context of enterprise and U.S. AML strategy, build an interactive relationship between the lines of business, control functions and the AML organization to discuss current and emerging/new AML risks and initiate and facilitate productive forums, in which senior management and the AMLROs can discuss, debate, and decide on key AML concerns
• Participating in Business Unit strategy sessions to ensure alignment and compliance with the AML program and policies
• Make recommendations and/or approve AML Business operating models, frameworks, risk management policies, etc.
• Enhance the Customer Risk Scoring program utilizing data analysis, regulatory feedback, new risk typologies and internal stakeholder feedback
• Provide input to the development of Business budgets & headcount to ensure alignment to AML risk
• Approve Business procedures and internal controls for adherence to AML Policy and Program
• Advise, educate and consult with Business leaders to ensure they fully understand the AML risks they assume and provide timely education to senior management on key risks,
• Ensuring AML policies and procedures comply with applicable current legislation and providing oversight of relevant Operating Group’s policies and procedures through ongoing monitoring
• Provide periodic reports & recommendations regarding AML compliance issues to senior management and the U.S. CAMLO.
• Implement any necessary changes and ensure required responsibilities are executed relative to the AML Policy and Program for BMO U.S., its subsidiaries and Branches and Agency.
• Serve as a point of contact for AML related regulatory agency, audit (internal/external) and management inquiries.
• Communicate changes to regulatory requirements to affected legal entities and Business Units/LoBs.
• Provide advice and recommendations on responses to regulators.
• Support the development and successful deployment of AML training programs
• Develop and implement an assessment of inherent risks and ongoing assessment of controls
• Using a U.S. view, establish team goals, objectives, policies and operating procedures ensuring alignment with the U.S. CAMLO and overall enterprise AML goals and objectives.
• Recommend and implement any necessary changes and oversee to ensure the performance of required responsibilities relative to the AML Policy and Program for the enterprise, its subsidiaries.
• Participate as a key member of the U.S. AML leadership team overseeing strategic and operational risk management processes of the AML organization.
• Staying abreast of new and developing customers, products and services. This includes, but not limited to Virtual currencies, Block chain, Marijuana Related Businesses, MSBs, Third Party Payment Processes, and Correspondent Banks.
Ensures the appropriate risk management and control framework of AML matters is in place across the Management of U.S. risk appetites. Includes:
• Independently establishes, monitors and oversees the risk management framework and key principles under which BMO operates to ensure compliance with regulatory requirements and risk management principles for AML measures and provides the required transparency for management, Board and regulators
• Monitoring the integrity of data and systems required for the appropriate risk management and control of AML risks and follows up with management with pace with respect to AML risk mitigation activities. Reporting to Senior Management, as appropriate, whether systems, resources, including those required to identify and report suspicious transactions and suspicious attempted transactions or activity in relevant jurisdictions, are sufficient in all relevant Operating Groups
• Ensures proper risk checks and balances and controls systems are in place across the lines of business and control functions to enable adherence to and effectiveness of key controls, monitoring exposures and recommending and monitoring remediation activities
• Notifying and advising relevant operating groups and enforcing AML Risk Tolerance parameters or practices where appropriate
• Reporting pertinent information about the AML Program, including the sufficiency of the AML Programs resources to senior management and the Board and escalating risks and issues to appropriate stakeholders
• Partner with Corporate Audit, Compliance, Legal, Finance, Human Resources, and Technology and Operations to ensure internal controls and organization structures meet Corporate Policy Standards for Operational Risk and Duties of Care
Assess the effectiveness of AML and Sanctions controls for BMO’s U.S. lines of Businesses including having the required infrastructure, technology, and resources to deliver on business strategies, governance, and control. This Includes, but not limited to:
• Assessing the appropriate level and capability of talent for AML related roles in the first line of defense. This includes considerations of talent turnover and adequate succession planning.
• By extension, ensuring the U.S. Risk Management teams are appropriately trained, are aware of, as applicable, the implications of AML rules and regulatory requirements, changes in legislation, regulator expectations, legal developments and developments in AML practices and maintaining or facilitating access to current legislation
Ensures effective risk management performance for the U.S. AML offices including adherence with policies, practices and objectives of the U.S. AML function and in alignment with regulatory expectations. Oversight and effective challenge of the first line AML units and functions and ensures integration with the U.S. AML and enterprise office and in accordance with the U.S. and Enterprise AML function. Includes:
• Responsible for all areas of AML at senior management committees and supports north-south alignment for AML.
• Approves the development of the appropriate organizational structure that supports the needs of the business.
• Exert informed influence and effective challenge with both U.S. and Enterprise business and function leaders to ensure goal achievement, sound management of AML risks and regulatory compliance to drive the effective management of the U.S. AML programs.
• Ensures the data and management information systems operation adheres to applicable laws and regulations.
• Bring visibility to the AML risks relative to peers and sought for input and guidance for significant AML matters
• Stay abreast of AML risk trends and objectively/independently inform the U.S. CAMLO and the U.S. AML Leadership team on necessary enhancements across the organization
• Active participant in industry groups to stay abreast of current trends and techniques to mitigate risk
• Ensure U.S. Risk Management teams joins site visits of highest of high risk customers
• Conquers or challenges first line onboarding decisions for highest of high risk customers
• Suggests additional controls as required within the first and second line AML teams to mitigate risks
Providing transparency for key stakeholders, including employees, business leaders, executive management, the board, and regulators. Includes:
• Consultation with key business stakeholders to define business objectives and ensure they are aligned with the U.S. and enterprise AML policies, procedures and frameworks
• Establish procedures to provide early warning of potential failure to meet AML risk management objectives; ensure all activities that expose the Bank to AML risk are identified, understood, quantified, documented and mitigated as appropriate.
• Maintains a robust system of reporting that facilitates ongoing monitoring of AML risk positions
• Provides executive management and U.S. AML leadership team risk information to be included in BMO U.S. Risk Management Committees, Audit Committees and the enterprise AML organization timely and accurate information on the AML risk profile of the operation
• Represent the U.S. AML Office at key management committees including the Regulatory, Compliance and Operation Risk Committee (RCOC) and others.
• Maintain and continuously improve BMO’s AML framework and ensure proper checks and balances and control systems are in place across the organization
• Provide oversight and effective challenge to ensure the effectiveness and efficiency of AML risk controls for business processes and practices;
• Build a high-performance culture within the AML organization where speedy execution and issue resolution, business value creation, and collaborative working relationships are everyone’s objective.
• Embed AML risk awareness and the three lines of defense model into mindset and operations.
• Provide a safe haven where an employee can report risk issues and concerns
Qualifications
• 10 + years’ experience managing and/or directing complex organization.
• Expert Knowledge of up-to-date AML and Sanctions practices
• Expert Knowledge of the U.S. regulations related to AML and Sanctions, and implementing regulations
• Understands the U.S. AML regulatory affairs
• Successful initiation and execution of tough decisions/choices re: people, business priorities, and strategy
• Considerable knowledge of business theory, business processes, management, budgeting, and business office operations.
• Understands matrix structures—how to make them effective & how to personally function successfully within them
• Diagnoses whether the organization is performing at its full potential and generates or influences corrective action
• Understands matrix structures—how to make them effective & how to personally function successfully within them
• Diagnoses whether the organization is performing at its full potential and generates or influences corrective action
• Changes the business by being decisive and incisive
• Builds and sustains a culture of innovation and change
• Demonstrates sound judgment and deep knowledge of the relationship between level of return and risk tolerance
• Ability to quantify and articulate risk vs reward decisions in a matter that is easily understood by various levels of employees and management
• Ability to assess risk in new products and services
• Knowledge of regulatory bodies and effective management of their representatives
We’re here to help
At BMO Harris Bank we have a shared purpose; we put the customer at the center of everything we do – helping people is in our DNA. For 200 years we have thought about the future—the future of our customers, our communities and our people. We help our customers and our communities by working together, innovating and pushing boundaries to bring them our very best every day. Together we’re changing the way people think about a bank.
As a member of the BMO Harris Bank team you are valued, respected and heard, and you have more ways to grow and make an impact. We strive to help you make an impact from day one – for yourself and our customers. We’ll support you with the tools and resources you need to reach new milestones, as you help our customers reach theirs. From in-depth training and coaching, to manager support and network-building opportunities, we’ll help you gain valuable experience, and broaden your skillset.
BMO Harris Bank is committed to an inclusive, equitable and accessible workplace. By learning from each other’s differences, we gain strength through our people and our perspectives. BMO Harris Bank is an Equal Opportunity Employer for all, inclusive of Minorities, Women, Veterans, and Persons with Disabilities.