Manager, Sanctions

Operating in the UAE for over 50 years, CBD manages the financial requirements of some of the largest corporates and businesses operating in the country, driving the UAE economy. Over the years, CBD has transformed into a progressive and modern banking institution winning multiple awards for its digital initiatives, credit cards, bank accounts, mobile app features and services.

CBD has been recognized as the number one bank in the UAE on the Forbes list of The World's Best Banks 2022.

As we continue to build upon our successes, we are looking for ambitious individuals who are passionate about the banking and finance industry and the markets in which CBD operates. Just as important to us is your ability to demonstrate a talent for dealing with people - your colleagues and our customers - and delivering service that really goes the extra mile. 

The role holder is responsible for managing the Sanctions function, managing and mitigating Sanctions risk throughout the Bank, as well as providing subject matter expertise to senior management. General Managers, and business stakeholders. The role holder is also act as the main point of contact with the Central Bank on Sanctions matters and engaging with Correspondent Banks on Compliance queries.  

Responsibilities

• Ensure compliance with applicable sanctions laws and regulations as well as applicable sanctions international lists. Provide the Head of Compliance with assurance that controls required under sanctions regulations are embedded within the Bank's processes to avoid any sanctions breach and/or establishing relationship with a sanction listed party.
• Responsible for advising on a wide range of international trade, regulations, economic sanctions and other compliance related issues. Good knowledge of EU, UK and international law and regulations.
• Manage external communication with correspondent banks to ensure timely responses are provided.
• Escalate sanctions related cases to the Head of Compliance to ensure awareness and report to CB where necessary
• Review and investigate all breaches, discrepancies and irregular activities, and recommend corrective actions to ensure compliance with the Bank's Sanctions policies/procedures and mitigation of identified risks for the bank.
• Support the effective management of key compliance systems used by the team to conduct customer and transaction sanctions screening. 
• Define and ensure integrity of all Sanctions Lists for payment and on-boarding systems to ensure the bank is not exposed to any risk of dealing with a sanctioned person and/or entity.
• Supervise the handling of sanctions alerts process based on the Management Information (MI) reports. Prepare periodic Sanctions reports to provide the Bank's senior management with an update on the operations and effectiveness of the Sanctions function. 
• Manage sanctions related entries in the internal watch lists used for customer and transaction screening. 
• Assess the effectiveness of the parameters set up in the systems for sanctions screening and the percentage for matching dependent on the type of screening conducted.
• Ensure the right level of governance around the implementation of sanctions lists. Define a change management process to ensure there is sufficient governance and oversight of changes. 
• Ensure that all transactions are subject to sanctions screening.
• Assess on a periodic basis the customer screening procedures at the time of on boarding as well as the ongoing screening of the Bank's customer base. 
• Manage the implementation of new Sanctions systems – including designing and developing rules that are fit-for purpose and define system requirements, parameters, scenarios, logic and underlying rules.
• Stay abreast of new sanctions regulations and communicate all relevant changes to the business lines. Conduct bank-wide sanctions training on relevant sanctions regulations. 
• Provide guidance and training to sanctions investigation analysts and relevant staff on implementation of sanctions regulations, policies and procedures.
• Liaise with legal and external counsel on sanctions matters that arise when required.
• Provide updates to the wider AML/CFT and Sanctions team on current events or regulatory changes.
• Ensure the Sanctions related policies and procedures remain updated and communicated as required to all stakeholders.
• Implementation of a Sanctions escalation matrix, in order to ensure that all approvals, exemptions to the policy and requests for information (RFIs) are addressed in a timely manner.
• Support the team by reviewing transactions or Requests for Information (RFIs) from Correspondent Banks when the volume is higher than the average or when there are staffing constraints that would limit the team's capacity.
• Provide guidance to the Sanctions Senior Officers on their investigations.
• Supervise the Quality Assurance process to review closed alerts and cases on a sample basis.
• Review Sanctions related training materials (i.e. e-learnings and face-to-face) and participate in the delivery of face-to-face trainings.
• Log and escalate all Sanctions breaches or potential breaches.
• Manage the available resources efficiently and prioritize system enhancement/up-grades.

• Bachelor's Degree as a minimum from a recognized university.
• CAMS or ICA or CFCS or CRCMP is mandated.  
• At least 12+ years of experience in the banking/financial services sector (including four years in a sanctions compliance role)
• AML/CFT, Sanctions, Training, Rule Management, Written Communication, Regulatory Relationship, Quality Control Analysis, Critical Thinking, Judgment and Decision Making, Complex Problem Solving, Social Perceptiveness
• Familiar with OFAC, EU, UN, UAE and OFSI sanctions regime.