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Role Purpose

The VP - IR is a key strategic risk management role that has a broad remit, accountability and responsibility for supporting the Head IR in implementing policy for the anti-money laundering (“AML”) and counter-terrorist financing (“CTF”) (collectively referred to herein as “AML”) Investigations, risk management framework to meet AML requirements and legislation in India. This includes providing oversight and management of AML Investigations including impact analysis of regulatory changes, and driving coordination and execution of the various FCI – Investigations work streams and assurance, while ensuring alignment with the framework laid down by the Group.

The role requires strong partnership with the lines of business (LOB), Global Functions (GFs) and FCC teams, acting in concert with them to drive the implementation of FCI framework. It will monitor and track the progress of various work streams and initiatives underway which fall under the umbrella of Investigations Work-stream under Financial Crime Compliance, provide policy advice related to all business line products, services and clients, and ensure that the FCI function is resourced adequately to address the risks associated with all business lines in India.

The role will also need to stay at the forefront of key changes to ensure proactive communication with the business and develop appropriate policy and framework to manage the changes, particularly extra territorial changes. The role holder will be the go-to person for the work stream leads to ensure processes are coordinated and implementation risks and issues are considered and addressed.

The role is a forward looking role and requires strong partnership with business to drive and accelerate the AML programme and assist in the execution of the Investigative Reporting function under FCI that directly impact business performance.

· Work with relevant contacts in Global Businesses and Global Functions to ensure consistent and effective application, and implementation, and controls to evidence related with Investigative Reporting standards, policies and procedures.

· Act as principal point of contact for internal and external stakeholders in relation to Transaction Monitoring/Investigation risk (including regulators)

· Accountable to the country Head of IR FCI for driving the effective risk mitigation through transaction monitoring and investigation function by meeting the quality and efficiency objectives

· Stay at the forefront of key regulatory changes to ensure proactive communication with business and implement appropriate group policy and framework to manage the changes.

· Provide advice to business across India on risk associated with prospective business, products and service and design mitigation controls and strategies as appropriate.

· Intersecting and representing FCC/FCI with senior business leadership.

· Act as the Alternate Principal Officer with FIU IND, for the Bank and manage all regulatory reporting and interactions with the regulator.

Key activities and decision making areas

Impact on the Business / Function

· Support Head IR in driving delivery of objectives in line with organisational strategy - implement communications strategy, for standards, systems and policies, regarding FCC topics in India.

· Identify, assess, oversee and communicate all requirements relating to AML regulatory guidance and law enforcement trends regarding INM’s business activities.

· Implement criteria for integration and analysis of suspicious activity surveillance and reporting results, escalation of analysis and events across India.

· Ensure that the Group’s exposure to regulatory and reputational risks is managed at a country level, in a commercially sensible, practical and cost effective manner.

· Discharge the relevant accountabilities as set out in the Group FCC standards framework in India.

· Manage and lead the required remedial action of all material FCC issues involving India that arise to ensure effective implementation, through internal and external reviews.

· Implement satisfaction of the Bank’s requirements and commitments under the enforcement actions emanating from any regulatory authorities

· Leadership to drive, develop and implement programmes to quantify impacts and implement actions to address and mitigate impacts of AML risk embedded in client activity within the country.

· Establish and implement global standards and strategic policies which ensure exposure to current and emerging risks are managed effectively

· Manage all regulatory reporting and interactions.

Customers / Stakeholders

· Support the India Head of IR in the provision of reports on a country wide basis to the EXCO/RMM (and, as necessary, regulators) on TM issues.

· Ensure that the India Head of IR is appropriately advised of material AML issues in India.

· Work effectively with principal regulators and industry bodies on AML matters.

· Lead / liaison with relevant stakeholder within Global Business and Country teams to provide expertise and support on all FCC related matters.

Leadership Teamwork

· Support India Head of IR FCI, Develop and deliver the strategy for the IR function.

· Coordinate between FCC Compliance, Regulatory Compliance, Global Business, Risk, Technology, Internal Audit, and Legal, and others as appropriate in India.

· Foster positive and professional working relationships within RC and FCC and other senior managers throughout India

· Be accountable for developing, setting and deliver the FCC strategy for the country.

· Maintain and develop positive and professional working relationships with senior business managers at the Regional and Country levels.

Operational Effectiveness Control

· Be creative/innovative in implementing Group policies

· Maintain awareness of operational risk within assigned portfolio and minimise the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.

· Maintain and observe all HSBC control standards and implement and observe the Group Compliance Policy, including the timely implementation of recommendations made by internal/external auditors and external regulators in India.

Major Challenges

To take the complexity of the regulations on the one hand, and the diversity of business and geographies within India, and achieve a balance between the demands of the regulators, external bodies and governmental initiatives and the Group’s shareholders and customers; being alive to the political, management, operational, regulatory and reputational implications of particular decisions and courses of action; assisting senior management in development of controls and systems and influencing the way in which business is conducted in order to manage these risks.

In order to effectively manage change in a volatile environment, the jobholder is required to have a broad and deep understanding of businesses, regulatory and industry issues, as well as the competitive landscape. The incumbent will be required to stay abreast of the rapidly changing regulatory environment as it relates to Financial Crime Compliance and the more stringent regulatory interface and intervention across multiple jurisdictions, which is complicated further given the dynamic nature and differing pace of change.

The incumbent is required to ensure the consistent application of the highest Risk management standards notwithstanding the complexities of products and business operations in India. Risk is forward looking. The incumbent would implement and drive change programmes to ensure that IR-FCI remains in line with regulatory requirements across India. A balance must be maintained between the local, regional and global priorities. The incumbent would need to balance between sometimes conflicting needs and priorities of different teams within Risk departments and across countries.

Role Context

India is an emerging economy and a strategic priority for the Group. It is a developing regulatory jurisdiction, which is regulated by multiple regulators not only within India (e.g. RBI, SEBI) but also from overseas (i.e. HKMA). While the regulations are voluminous and complex; sometimes prescriptive; sometimes ambiguous and sometimes archaic, the operating environment on the other hand is dynamic, demanding and diverse with multiple stakeholders.

The RBI primarily regulates the Bank’s business in India. Its regulations are complex requiring interpretation and subject to frequent amendments and clarification. RBI is increasingly delegating the monitoring of its policies and regulations to banks and accordingly the observance of directives/guidelines is now generally the responsibility of banks which increases the inherent risks. For example, the recent guidelines on risk based supervision has increased the pressure on the Compliance function. Whilst foreign exchange regulations have been relaxed, greater responsibilities have been placed upon banks to ensure that the revised guidelines are implemented.

Over the last few years, the Financial Intelligence Unit – India (FIU-IND) has also been interacting very closely with the banking industry and has been recommending implementation of a risk based framework, improving the mechanism for reporting, improving AML systems for capturing various AML red flag indicators etc. This adds to the challenge to the role as the role holder would be primarily responsible for driving the implementation of these changes within India.

The economic and business environment contributes to the growing compliance risk profile of the Global businesses. Competition from peer foreign banks has increased with the setting up of branches by several foreign banks; local private banks also service the same customer segment and their increasing footprint puts pressure on business. Knowledge of products and importantly, practices of competition is an absolute necessity.

The Global businesses are largely people intensive and require continuous Compliance focus with regard to compliance to financial crime. The VP - IR (FCI) would be responsible to have an oversight on all activities pertaining to IR in the Global businesses to mitigate the AML/Transaction Monitoring Reporting risks.

Management Leadership of Regulatory, Compliance Operational Risk

The jobholder is responsible for ensuring that the FCC AML standards are maintained in accordance with the Global Standards Manual and that the AML policy aspects of the Compliance FIM are effective and relevant, in conjunction with country regulations.

Observation of Internal Controls

· Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators in India.

· Jobholder is required to manage Country FCI/FCC responses to adverse Compliance metrics, including unsatisfactory FCI Reviews and Audit reports.

· This will be achieved by adhering to all relevant processes/procedures and by liaising with Financial Crime Compliance and Regulatory Compliance departments about new business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimising relations with regulators.

· The jobholder will also adhere to and be able to demonstrate adherence to internal controls. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators.

Role Dimensions

The jobholder’s responsibilities cover supporting the Country Head of AML.