Director, Anti-Bribery & Corruption CoE – Standard Chartered Singapore

The role holder is expected to act with full autonomy under authority delegated by the Global Head, Anti-Bribery & Corruption (“ABC”) and will report directly to the Head, ABC Centre of Excellence (“COE”) East. The role will work within the ABC COE East Team, that oversees ABC program in Asia Region of the Bank.

The role will serve in an advisory capacity for all ABC escalations to the ABC COE East. This includes, but is not limited to the following:

• Providing SME advisory on bribery and corruption risks in M&A, Corporate Finance, Corporate Development and other complex transactions
• Acting as a point of contact for business, functions and country inquiries within Asia Region (East)
• Preparing papers, when appropriate, for the relevant Country Financial Crime Risk Committees (“CFCRCs”).
• Developing and providing training to local business and functions.
• In addition, the role will take lead for the ABC COE for the following areas:
• Leading and supporting ABC Group Risk Assessment, including advising on developing the methodology for inherent risk, control effectiveness, residual risk protocols and determinations and leading on calibration of results.
• The role will also lead Group ABC advisory work for dedicated functions/segment stakeholders, and act as a Risk Owner Delegate (“ROD”) for these functions/segments.
• The role holder will also support the various projects across the ABC COE

Strategy

• Provide input to Group/Region/Country/Business/Functions operating model design of ABC and business processes.
• Implement the vision, strategy, direction and leadership for ABC in the East, consistent with the vision and strategy for FCC and in support of the Group’s strategic direction and growth aspirations.
• Monitor horizon risks in ABC activities that may have a significant impact on the Group and develop effective strategies to mitigate such horizon risks, including participating in “lessons learnt” initiatives (e.g., write ups for mass distribution and for ABC Country Lead Forum distribution).

Business

• Ensure that key changes (to laws, rules, regulations) are communicated and cascaded (in Region/Country) to relevant stakeholders, in coordination with group communications.
• Support the Head, ABC COE East and relevant stakeholders to make risk-based decisions guided by Group ABC policies, practices, and trends.
• Provide advice to relevant stakeholders on the interpretation and application of regulatory expectations, laws, best practices, policies, global standards and risk management activities related to ABC in the East and at Group.
• Challenge, where necessary, stakeholders on effectiveness of ABC processes, risk and control framework.

Processes

• Support the implementation of ABC related policies and procedures in the East and at Group to ensure they effectively mitigate ABC risk.
• Support in the design, implementation and evaluation of ABC controls to effectively mitigate ABC risk in Business and Functions.
• Ensure key ABC risks and issues are being analysed, reported, escalated and tracked appropriately both at Country, Regional and Group level to the relevant governance bodies. Evaluate and advise on reputational and regulatory risk arising from customers, third- parties and transactions in accordance with embedded risk management framework.
• Advise on the Global ABC Programme and supporting initiatives to continuously improve the ABC control framework and stakeholders’ engagement.
• Develop and deliver approved ABC training to the relevant stakeholders in the East, as necessary.
• Work with Legal and Compliance to interface with regulators, government agencies and law enforcement on ABC matters relating to investigations, where necessary.

People and Talent

• Promote and embed the Bank’s values within the Group, Region, and Countries, including a culture of openness, trust and risk awareness, where ethical, legal, regulatory and policy compliant conduct is the norm.
• Support an environment where forward planning, prioritisation, deadline management and streamlined workflows and collaborative, inclusive yet effective and efficient work practices are the norm.
• Collaborate with training teams to input to training curriculum to support closing of capability gaps.

Risk Management

• Act as lead for the ABC COE on implementation of the ABC Group Risk Assessment.
• Be vigilant, identify, and escalate potential = regulatory breaches (or where risk tolerances have been breached) and ensure that action plans are developed, tracked, and delivered timely quickly to remediate and/or activities are ceased.
• Provide recommendations (and/or implement) to relevant stakeholders on risk management responses to identified ABC risks and/or findings from internal Audit/Assurance reviews, investigations, or external reviews undertaken at the Country, Regional and Group level.
• Implement ABC risks identification and assessment methodologies and advise relevant stakeholders on outcomes.
• Support the Head, ABC COE East in defining and executing the applicable control standards under the ABC GRA and Operational Risk Framework (“ORF”).
• Engage with relevant stakeholders to ensure appropriate compliance testing, risk assessment and assurance testing in place for ABC risk areas over which Group Head, Anti- Bribery and Corruption, has authority.

Governance

• Support senior management oversight and leadership on ABC matters to leadership forums/meetings at the Country, Regional and Group level.
• Represent the Global ABC Programme as Risk Owner Delegate for Global Business and Functions as appropriate.
• Analyse and interpret Group ABC metrics and management information and advice on development of necessary Regional metrics and MI to identify and manage emerging areas of risk / vulnerability, and to produce reports to relevant stakeholders and committees to drive remediation action within the ABC Programme.
• Ensure that any changes to the Global ABC standards, control framework and processes are reviewed and approved by the Group Head, Anti-Bribery and Corruption.
• Collaborate with relevant stakeholders to ensure that surveillance and investigation findings relevant to ABC are appropriately tracked and escalated.
• Prepare, oversee and cascade ABC communications relevant to the East.
• Support the Head, ABC COE East in ensuring that ORF testing and reporting around ABC risks remains effective.

Regulatory & Business Conduct

• Display exemplary conduct and live by the Group’s Values and Code of Conduct. Take personal responsibility for embedding the highest standards of ethics, including regulatory and business conduct, across Standard Chartered Bank. This includes understanding and ensuring compliance with, in letter and spirit, all applicable laws, regulations, guidelines and the Group Code of Conduct.
• Support the Head, ABC COE East to ensure the team achieves the outcomes set out in the Bank’s Conduct Principles: Fair Outcomes for Clients; Effective Operation of Financial Markets; Financial Crime Prevention; The Right Environment.
• Effectively and collaboratively identify, escalate, mitigate and resolve risk, conduct and compliance matters.

Key Stakeholders

• ABC Process Owners / Business and Functions.
• Group Colleague Conduct team, including ABC COE Team members, ABC Oversight Group Members, Regional and Country CFCC Stakeholders.
• Shared Investigative Services
• Enterprise Risk Management team
• Group Operational Risk
• Process Owners at Group, Business and Function levels

Other Responsibilities

• Embed Here for good and Group’s brand and values in Group ABC team and in the East. Perform other responsibilities assigned under Group, Country, Business or Functional policies and procedures.

• 8 plus years of experience in management of bribery and corruption risks, deal advisory and compliance in a large multinational financial institution, consulting firm or law firm in a similar role.
• Strong knowledge of U.S. Foreign Corrupt Practices Act (“FCPA”) and UK Bribery Act (“UKBA”) is must
• Subject matter expertise in assessing and managing bribery risk and violations of the FCPA, UKBA and other anti-corruption laws.
• Sharp business acumen (including ability to assess risk and appropriate levels of return), strong leadership qualities, excellent interpersonal skills and cultural awareness and sensitivity.
• Ability to collaborate and work dynamically across country, region, business and group stakeholders.
• Understanding of best practice risk management techniques and frameworks relating to ABC.
• Sound judgement on business practices, regulatory relationship management and reputational risk.
• Relevant ABC and financial crime qualifications/accreditations, ACAMs, ACFE, other is bonus
• Bachelor’s degree from an accredited institution, or equivalent or a bachelor’s degree in another area with a law degree, both from accredited institution or equivalent.