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Anti-Money Laundering and Counter Terrorist Financing Regulated Business Lead

The primary role of the Anti-Money Laundering and Counter Terrorist Financing (
AML/CTF
) Regulated Business Lead is to lead Accenture’s AML Centre of Excellence (
CoE)
and be responsible for the oversight of the local Anti-Money Laundering Compliance Officers (
AMLCOs
) across the Globe. The role will provide independent challenge, steer and support to the AMLCOs, who are in turn responsible for the day-to-day operation of the AML regulated programs in their respective legal entities.

The AML/CTF Regulated Business Lead is responsible for the strategic design and updating of consistent Global AML/CTF standards including by defining and disseminating common processes, templates and frameworks by which the AMLCOs will operate. They will also share best practices amongst the global AMLCO network and drive accountability of the AMLCOs in the operation of each local AML programme.

The AML/CTF Regulated Business Lead will report to the Global Director for Trade, AML and CTF.
Scope of Responsibilities

:

The AML/CTF Regulated Business Lead will be expected to perform the following activities:
Participate and execute key decisions for the creation of new AML/CTF Regulated Programmes or the dissolution of these programmes as required in relation to new business expansions globally (e.g. crypto) and/or expansion of licensed/regulated activities (e.g. insurance/payment services);

Defining duties for, appointing/hiring of and onboarding appropriate individuals to fulfil the AMLCO and AML Delegate roles in each of Accenture’s regulated entities subject to local AML laws and regulations.

Providing first level approval for all local AML/CTF policies and procedures for regulated entities prior to formal local Board or Senior Leadership final approval.

Defining and communicating KYC standards to be adhered to by the local AMLCOs in their capacity as executors of the AML framework in their respective legal entity.

Analyzing the outcomes and implementing remedial action to address findings identified through LCM monitoring of the red flag escalation and KYC processes.

Ensuring the implementation of remedial action/resolving gaps to address findings/outcomes of formal reviews (including, but not limited to, the global AML programme audit, Company Risk Assessment and external counsel reviews).

Performing periodic desk reviews in the local market of each AMLCO to maintain oversight over the operation of each local AML programme and identify any challenges to facilitate timely resolution.

SUPPORT

Regularly monitoring for regulatory/legal updates and tracking changes both locally and globally with support from selected local counsel. The AML/CTF Regulated Business Lead will also liaise with local AMLCOs to ensure relevant updates are appropriately identified, evaluated and factored into each AMLCO’s respective programme.

Acting as a point of consultation and/or support for the AML Programme Director and Global AML Team as required to provide input into global AML-related initiatives, including (but not limited to):

Global Accenture Leadership and/or Board reporting;
Global AML Programme Risk Assessment and controls evaluations;
Definition of AML Risk Aids and AML Handbooks;
Practical prospective business venture support, such as pertaining to expansion of existing scope of services or mergers/acquisitions;
Global AML policies and procedures;
Contracts and RFPs containing AML elements;
Definition of predicate offences and red flags applicable to Accenture’s global operating footprint;
CBT requirements for higher risk employees in non-AML regulated areas of Accenture’s business model; and
Global internal or external AML programme reviews.

REGULATORY ENGAGEMENT

Engaging with regulatory bodies related to any regulatory investigations, remediations or other matters.
Working with auditors (internal and external) with regard to the AML programme and monitoring implementation of audit points or regulatory findings
Contributing to thought leadership articles or regulatory consultations related to AML

TRAINING

Working in conjunction with the local AMLCOs, designing Accenture’s AML CBT programme.

Designing and delivering:
Tailored AML/CTF training required to be undertaken by AMLCOs and their Deputies/Delegates; and
Local relevant awareness-raising and issue spotting initiatives, identified in conjunction with input from local AMLCOs as a result of internal or external triggers.

Setting the standard for and ensuring the completion of any agreed formal AML accreditation/certification programs by the AMLCOs (and their Delegate, if considered necessary).

Relationships:

Reports to:
the AML Programme Director

Relationships:
Global AML Team, local AMLCOs for each legal entity, AML CoE, KYC Team, LCM Team.
Qualifications

Basic (Must-Have) Qualifications:
Education: Law degree as a minimum
Work Experience: Minimum of 7 years of relevant industry experience (e.g within Financial Institution, Law Firm or other In House Role). Experience in contentious issues preferred.

Work Requirements: Minimal travel required.

Knowledge and Skill Requirements:
Working knowledge of global anti-money laundering legal and regulatory frameworks and best practice, especially European and US. Working knowledge of other anti-financial crime frameworks, such as anti-bribery and corruption, beneficial; Experience of working with regulators, including investigations and/or remediations.

Knowledge, experience and understanding of the implementation of such frameworks in global corporations, preferably in the context of a decentralized operating model;

Knowledge and understanding of Accenture’s business vision and strategy (or similar business strategy at another company for an experienced hire);
Significant experience skillfully managing multiple stakeholders/business interests, including dealing with senior management, promoting consistency of approach whilst remaining independent;

Able to assess risk and recommend action on a proportionate risk-based approach;
Good judgement, an ability to prioritize and make decisions in a timely manner, and a high level of common sense;
Significant experience leading large projects and teams;
Ability to collaborate with team members and other peers across various business divisions;
Excellent stakeholder and risk management skills;
Excellent writing and negotiation skills;
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