Overview
The Financial Crime Compliance (FCC), Policy & Framework Lead (CM) provides senior second line leadership for the Corporate Markets business.
The role supports the Head of FCC, AMLCO, in ensuring statutory and regulatory obligations are met across Corporate Markets and provides continuity of leadership, independent challenge and sound judgement for material Financial Crime matters.
The role focuses on providing expert guidance and advice while developing, updating, and executing FCC policies, processes, and procedures. It includes responsibility for reviewing and assessing financial crime risks and AML/CTF program to ensure consistency and alignment with Group standards, current and emerging legislation, and evolving business needs.
Key Accountabilities and main responsibilities
Strategic Focus
- Contribute to the design, implementation and continuous enhancement of the Financial Crime Compliance (FCC) framework, policies and standards.
- Provide strategic insight and regular reporting to the Head of FCC / AMLCO on financial crime risk exposure, compliance posture and mitigation strategies.
- Embed a strong compliance culture by promoting financial crime risk awareness, accountability and consistent risk-based decision making.
- Collaborate with Technology, Data and Operations teams to influence the future-state FCC technology roadmap, ensuring alignment with Group-wide detection and mitigation capabilities.
- Monitor emerging financial crime risks, typologies and regulatory expectations, and translate these into forward-looking policy and framework enhancements.
Operational Resilience
- Support the maintenance of a consistent, risk-based FCC / AML program covering all AML/CTF obligations, including CDD, KYC, transaction monitoring, risk assessments, reporting and record keeping.
- Partner with 1st Line of Defence (1LOD) to identify control gaps, emerging risks and systemic weaknesses across AML, sanctions and ABC.
- Oversee FCC assurance and QA activities relevant to Corporate Markets, including review of control testing, thematic reviews and assurance outcomes.
- Challenge remediation plans, track issue resolution and escalate material or systemic concerns where required.
- Support effective and compliant FCC system design by providing risk input into data quality, control effectiveness and technology change initiatives.
- Monitor and manage technology-related financial crime risks, issues and dependencies.
People Leadership
- Act as a trusted advisor to business leaders, AMLCO / MLROs and financial crime teams, providing clear, pragmatic and defensible advice.
- Translate complex regulatory requirements into practical, risk-based guidance for business application.
- Provide guidance on complex or high-risk AML, sanctions and ABC matters, supporting informed senior decision making.
- Promote consistency of FCC interpretation and outcomes across the business.
- Develop and deliver financial crime training across 1st and 2nd Lines of Defence, and promote ongoing awareness through workshops and stakeholder engagement.
- Represent FCC in regulatory, audit or governance forums where required, ensuring advice and decisions are clearly documented and defensible.
- Provide advice on sanctions risk associated with clients, transactions and products, ensuring alignment with Group policy and regulatory expectations.
- Collaborate closely with 1LOD to resolve complex, high-risk or sensitive issues.
Governance & Risk
- Provide 2nd Line of Defence oversight of sanctions risk and compliance for Corporate Markets, ensuring risks are identified, assessed and appropriately managed.
- Oversee sanctions screening governance, decision making and escalation processes, including review of material issues, breaches and complex judgement calls.
- Oversee Anti Bribery & Corruption (ABC) risk assessments, control design and issue management.
- Review material ABC incidents, allegations and control weaknesses, and provide senior guidance on ABC risks relating to clients, intermediaries and transactions.
- Ensure AML, sanctions and ABC risks are integrated into broader FCC governance frameworks.
- Support the AMLCO in regulatory engagement, supervisory reviews and information requests.
- Review regulatory submissions, correspondence and remediation plans, and provide authoritative advice on regulatory obligations and emerging expectations.
The above list of key accountabilities is not an exhaustive list and may change from time-to-time based on business needs.
Experience & Personal Attributes
- 8 yrs experience in FCC, AML/CTF or broader FCC risk within financial services.
- Experience in asset and wealth management is highly desirable
- Experience with Board and committee governance frameworks, including senior reporting and escalation.
- Demonstrated experience operating in a second line of defence (2LOD) role, with responsibility for governance, escalation and oversight.
- Strong working knowledge of AML/CTF regulatory obligations, including suspicious matter reporting, risk assessments and governance frameworks.
- Proven experience partnering with 1LOD Financial Crime teams to influence risk outcomes while maintaining appropriate independence.
- Understand how financial crime risk aligns with business strategy
- Experience engaging with regulators, internal audit and external reviewers, including response preparation and remediation oversight.
- Ability to balance commercial objectives with regulatory expectations
- Track record of exercising sound judgement in complex, high risk or ambiguous situations.
- Experience providing FCC input into technology change or transformation initiatives.
MUFG Pension & Market Services is a global, digitally enabled business that empowers a brighter future by connecting millions of people with their assets – safely, securely and responsibly.
Through our two businesses MUFG Retirement Solutions and MUFG Corporate Markets, we partner with a diversified portfolio of global clients to provide robust, efficient and scalable services, purpose-built solutions and modern technology platforms that deliver world class outcomes and experiences.
A member of MUFG, a global financial group, we help manage regulatory complexity, improve data management and connect people with their assets, through exceptional user experience that leverages the expertise of our people combined with scalable technology, digital connectivity and data insights.
