Deputy Head of Financial Crime Compliance & MLRO

About the Role:
The MLRO & Deputy Head of Financial Crime Compliance (FCC) is responsible for establishing and overseeing an effective and sustainable Anti Money Laundering (AML) program across the company. This role involves ensuring compliance with applicable FCC laws, regulations, and the company's policies and procedures. The individual will lead the AML unit and manage areas including AML/CTF (Anti-Money Laundering/Counter-Terrorism Financing), anti-bribery, and corruption.

Key Accountabilities of the Role:

Strategic Contribution

• Ensure effective implementation and oversight of the Group's Compliance strategy within the AML team's remit for vertical alignment and horizontal integration with other departmental strategies.

People Management

• Set and approve core competencies of AML roles.
• Develop a capable AML team with good technical competence and collaborate with Unit Heads of Sanctions and CDD/ODD to staff the FCC function accordingly.
• Provide guidance and coaching to direct reports, acting as a role model to drive adherence to organizational values and foster a value-driven culture within the Group.

Budgeting and Financial Planning

• Review and recommend the AML team's budget to the Group Head of Compliance and monitor adherence to budget, ensuring all activities align with approved guidelines.

Policies and Processes

• Ensure the company maintains updated FCC governance documents (e.g., AML policies, procedures, risk assessment methodologies) to comply with all local regulations and best practices.
• Contribute as a thought-leader to evaluate and refine FCC and AML policies and processes, implementing best practices at a Group level.
• Identify opportunities for continuous and sustainable improvement in FCC-related systems, processes, and practices.

Financial Crime Compliance

• Establish and lead the AML function within the Group Compliance Department (GCD).
• Build the Group FCC framework based on best international practices and in compliance with local laws.
• Oversee the Group-wide implementation of FCC controls in conjunction with the Unit Heads of Sanctions and CDD/ODD.
• Ensure the company complies with all relevant FCC regulations and assess their impact on the company.
• Monitor activities at the Compliance Operations Center (COC) and ensure governance and feedback are constant.
• Review management information (MIs) pertaining to monitoring operations at COC, identifying anomalies and trends to manage risk and improve efficiency.
• Ensure teams at COC are appropriately sized to meet service level agreements (SLAs) while managing the budget effectively.
• Ensure process and resource deficiencies are identified and rectified promptly.
• Attend industry events relating to FCC to stay updated on developments and best practices.
• Establish and manage FCC and AML-related risk models in collaboration with Unit Heads of Sanctions and CDD/ODD.
• Ensure AML policy violations are identified and escalated as necessary.
• Provide subject matter expert (SME) advice to business units on AML/CTF and ABAC, recommending compliance measures.
• Provide input on FCC training content and ensure the rollout of all mandatory training according to the compliance training plan.
• Lead face-to-face FCC training sessions as required.
• Assume the responsibilities of the company's Money Laundering Reporting Officer (MLRO) registered with the CBUAE.
• Build and maintain relationships with AML regulators.
• Ensure efficient processes are in place for staff to report suspicious transactions to Compliance.
• Oversee the production of all internal and external suspicious transaction reports (STRs).
• Manage Compliance's relationships with the company's Correspondent Banks, handling inquiries and signing AML/CTF/Sanctions questionnaires.
• Develop tactical and strategic solutions to FCC issues as they arise.
• Represent the company in regulatory inspections and support the Regulatory Affairs function in coordinating FCC-related communications.
• Ensure a framework exists for compliance and reporting required to regulators for AML predicate offenses, including collaboration with Fraud Risk Management.
• Manage the FCC Technology team and oversee the implementation and maintenance of FCC-related IT systems.
• Ensure internal and external audit recommendations against the FCC function are acted upon in collaboration with Unit Heads of Sanctions and CDD/ODD.
• Act as an SME to assist the Compliance Monitoring, Assurance and Testing (CMAT) team in AML-related assessments, tests, and reviews.
• Represent FCC in regular management meetings, supporting the Group Head of Compliance in Senior Management meetings.

Reporting

• Ensure the Group Board, Management Committees, Group Head of Compliance, and Senior Management are informed about critical AML plans, initiatives, and issues.
• Review and sign off on AML-related MIs for Committee and Senior Management meetings.
• Review AML investigation results and present findings to the Group Head of Compliance.
• Review all applicable reports before submission to regulatory/law enforcement authorities in UAE, including Suspicious Transactions/Activities Reports and the MLRO Report.

Relationships Across the 3LOD

• Liaise with Group Audit and Risk Management departments on FCC matters alongside Unit Heads of Sanctions and CDD/ODD.
• Engage with various business units to deliver a robust and integrated FCC program across the Group.

Specialist Skills / Technical Knowledge Required:

• Master's Degree in Science, Finance, Business, or a related subject; ACAMS certification or equivalent is preferred.
• Over 15 years of FCC experience acquired at a top-tier international bank, including 8-10 years managing large and complex AML/CTF/Sanctions teams.
• Proven experience advising or working in a Compliance function, focusing on delivering a robust FCC program.
• Strong track record in managing relationships with regulators and stakeholders.
• Exceptional interpersonal skills with the ability to communicate effectively, influence outcomes, and simplify complex issues into actionable recommendations.
• Comprehensive knowledge of FCC and relevant regulatory requirements for AML/CTF, Sanctions, KYC/CDD, and ABAC, particularly in the UAE and international jurisdictions such as Qatar, Iraq, and Sudan.
• In-depth understanding of international and cross-border regulations such as OFAC, UN, EU sanctions regimes, FATCA, FATF, and BIS.
• Ability to think innovatively to address complex problems while balancing risk, speed, and accuracy.