Anti-Financial Crime & Financial Crime Compliance
Leadership | Insight | Network

Compliance and Operational Risk Manager – Bank of America

The Compliance and Operational Risk (C&OR) Manager is responsible for engaging in activities to provide independent compliance and operational risk oversight of Front Line Unit or Control Function (“FLU/CF”) performance and any related third party/vendor relationships in alignment with the Global Compliance – Enterprise Policy, the Operational Risk Management – Enterprise Policy (collectively “the Policies”) and the Compliance and Operational Risk Management (“CORM”) Program and Standard Operating Procedures (SOPs). As a member of an FLU or CF C&OR officer team, the C&OR Manager is accountable for proactive identification, management and escalation of compliance and operational risks through the execution of some or all of the below identified activities. This role exercises judgment and influence, and may constructively challenge FLU and CF leaders to support the CORM Program objectives, balancing business strategy with appropriate controls.

The C&OR Manager proactively engages with other C&OR officers, including horizontal coverage owners and Enterprise Areas of Coverage (“EAC”), to provide comprehensive oversight of FLU/CF activities. This role develops and maintains a global coverage plan which defines the scope and risk-based focus of the second line’s risk management activities. The C&OR Manager prepares materials for C&OR regulatory exams/audits/inquiries and may provide consultation to business leaders in preparation for FLU/CF regulatory exams/audits/inquiries.

The C&OR Manager plans, drives and reviews team deliverables to support consistent quality of activities, processes and outputs. This role may contribute as a manager responsible for providing leadership direction to attract, assess, develop, motivate and retain a team, or may act as an individual contributor.

The C&OR Manager contributes to the requirements of the CORM Program requirements including, but not limited to the following activities:

  • Produces and/or oversees the development of independent risk management reporting for respective area(s) of coverage as input governance and management routines
  • Provides subject matter expertise to assist the FLU/CF in establishing an annual learning plan, may be accountable for developing and delivering training content
  • Develops and maintains C&OR-owned policies and standards and/or provides oversight of FLU/CF-owned policies, standards and procedures to ensure regulatory and operational risk requirements are appropriately addressed, inclusive of conduct risk as applicable
  • Monitors the regulatory environment to identify regulatory changes applicable to area(s) of coverage, advises business leaders on those changes, directs the appropriate areas to implement or amend policies, standards, procedures and/or processes to address regulatory requirements, and challenges the implementation plan as needed; maintains a comprehensive regulatory inventory
  • Identifies, aggregates, reports, escalates, inspects and challenges remediation plans, and performs thematic analysis on FLU/CF-owned issues and control enhancements
  • Ensures C&OR “owned” issues and control enhancements are identified and addressed appropriately and timely
  • Contributes to or leads development of risk coverage plans, executes and / or oversees execution of independent risk monitoring, testing and risk assessments, communicates results
  • Reviews and challenges the FLU/CF process, risk, control (PRC) inventory and FLU/CF Risk & Control Self-Assessment (RCSA)
  • Reviews and challenges internal and external operational loss events, including development of remediation plans to strengthen controls, and approves where appropriate
  • Participates in Scenario Analysis activities for coverage areas and challenges as appropriate
  • Ensures metrics are designed to measure key risks and control performance, monitors and reports on metric performance and breach remediation
  • Understand existing regulatory framework, emerging risks and industry best practice (related to Commodities, Futures, and Derivatives trading) in order to implement appropriate Compliance and Operational Risk controls, policies and procedures
  • Identify, report and escalate risks, issues and control enhancements to FLU/CF management
  • Manage and/or assist with addressing inquiries, exams and audits (by regulators, exchanges and internal groups)
  • Work with front line units to ensure day to day activities operate in compliance with laws, rules, and regulations
  • Provide advice and guidance to FLU/CF on applicable laws, rules and regulations
  • Provide oversight of operational risk matters such as operational loss events, and conduct periodic thematic reviews
  • Participate in strategic initiatives (internal or regulator-driven) in the Business and in Compliance and Operational Risk.
  • Identify training needs, conduct in-person training and contribute to training curriculum
  • Update relevant policies and procedures to reflect regulatory requirements for FLU/CF
  • Conduct risk assessments
  • Prepare annual CCO reports
  • Monitor the effectiveness of front-line risk controls
  • Oversee and assist the Enterprise Independent Testing team’s execution of trade surveillance and front-line tests
  • Assist in the execution of governance and management routines

Required Skills:

  • 10+ years’ experience in Commodities, Futures or Derivatives businesses
  • Strong knowledge of Derivative and Futures Markets operations and risks
  • Solid understanding of CFTC, NFA, and Futures exchange rules
  • Bachelor’s Degree
  • Solid experience in dealing with regulator and exchange inquiries and exams
  • Ability to think critically and proactively on the application of controls to evolving markets, systems, and risks
  • Strong verbal and written communication skills (ability to draft senior management and regulatory responses, monitoring/testing dispositions, policies, procedures, and training agendas)
  • Ability to work in a dynamic and fast-paced trading floor environment
  • Ability to focus attention on detail as well as multi-task
  • Proficiency in Microsoft Office (Word, Excel, PowerPoint, Outlook)

Desired Skills:

  • Operational Risk Management experience
  • Advanced degrees, securities licenses, or regulator experience a plus, but not required
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