BMO Financial Group Senior Manager, Capital Markets, Enterprise Anti Money Laundering in Toronto, Ontario
The Senior Manager, Capital Markets (CM) in Enterprise AML is accountable to oversee and lead the successful oversight and monitoring of the comprehensive AML Program across the Capital Markets Line of Business (LOB) / Legal Entities (LE) and/or jurisdictions of a BMO Operating Group (OG). Utilizing an understanding of both AML / ATF regulatory requirements and AML risk management requirements, the role is accountable to ensure the assessment of their impact from ‘end-to-end’ (i.e. from product origination through fulfillment) to processes, as assigned, throughout the OG. The role builds and maintains a network of relationships with senior executives across the bank and the AML Reporting Officer (AMLRO) for the OG to monitor the end-to-end AML regulatory and risk management profile and provide regular reports on the status of the AML program in the OG.
With guidance and context from the Director and AML Officer, the Senior Manager leads projects and initiatives which mitigate AML risk posed by the customers, products and operating geographies within an OG. The Senior Manager must possess knowledge of Global Trade & Banking, Investment & Corporate Banking, and Trading Products activities. As required by the Director and AML Officer, the Senior Manager liaises with various corporate functions, the AMLRO and LOB/LE Senior Management highlighting AML risks in the OG including regulatory exposure, material initiatives and systems issues or weaknesses in the control infrastructure. The individual acts as a key driver for change by reviewing and assessing AML legislation and risk management expectations. The role works closely with the AMLRO and leads projects which provide direction to develop, execute and monitor controls to ensure AML compliance and risk management requirements are managed. The Senior Manager also assists in the identification and management of AML risk typologies for the OG.
The Senior Manager supports the regular reporting on the state of AML compliance for LOBs / LEs and the OG as a whole. This role also serves as an interface for investigative units throughout the Bank to conduct their accountabilities. The role identifies emerging AML risks within industry which may impact the investigations conducted by groups across Bank, and raises these concerns on a proactive basis to train and improve the knowledge possessed by these groups.
Within the mandate of this role and BMO’s three lines of defense model, ensure business decisions and activities fall within the risk appetite of the Bank, and that internal controls are in place and functioning effectively to support management decision-making that protects our assets and adheres to applicable corporate policies, operating directives, laws and regulations (including risk, compliance, and AML).
Key Areas of Accountability
Guide the development and maintenance of AML regulatory compliance and risk management practices and procedures across the Operating Group on an end-to-end basis.
Guide the OG to implement a robust AML Risk Management Framework and AML Program including program strategy, standards, and tools based on Regulatory Requirements and Industry Practices.
- Provide access to and guidance on the AML Program to ensure that management is aware 1) of the Bank’s AML risk appetite, AML policy, authority structure, procedures and processes, and, 2) their own role and accountabilities in supporting these processes.
- Review AML policies, procedures, and standards, etc. for the LOB / LE in the OG which recognize the individual risks posed by the LOB / LE along with regulatory risk management expectations and which articulate the AML controls.
- Provide governance and oversight for AML related aspects of projects conducted within the OG. The role supports the development of practical solutions to AML implementation issues are identified and guides the businesses on the appropriate action to ensure continued compliance. The role is expected to provide leadership and subject matter expertise to project teams within the OG. Provide objective and independent AML expert advice and counsel to the LOB / LE Management teams across the OG under the direction of the Director or CAMLO.
- Lead the review and approval of assessment, mitigation and appropriateness of changes to 1st line business processes regarding AML risk within the OG in conjunction with the Director and AML Officer.
- Support the 1st line process for identifying and assessing the AML risk inherent in assigned OG initiatives including new products, processes, subsidiaries, joint ventures, outsourcing and acquisitions. Support the Line of Business to develop robust control processes which meet regulatory and internal requirements.
- Be instrumental in helping to build strong working relationships between front office, back office and technology areas of the bank to create an awareness of AML accountabilities throughout the OG and their partners.
Understand the OG (and the LOBs / LEs) strategies, boundaries, scope, opportunities and risk through ongoing dialogue with senior management.
Ensure that the OG Risk profile is aligned with strategic business objectives and the Enterprise stated risk appetite.
Maintain an understanding of potential risk scenarios where the OG may encounter money laundering or terrorist financing behaviour through constant research into emerging risk typologies.
- Where assigned by the Director, raise and highlight concerns where management is not fulfilling AML risk management responsibilities or have not developed sustainable processes and controls to ensure the continued management of AML risk.
- Proactively scan and make the Director aware of changes to AML risk tolerance in products, services, customers and geographies related to the OG.
- Identify AML risk management best practices and emerging risks which may impact the AML regulatory and risk mitigation strategies currently employed.
- For the lines of business which the Senior Manager has been tasked to oversee, ensure that the approach to monitor client and transactional risk adequately mitigates the risks posed by the operations of the Bank in a particular jurisdiction.
Communicate changes to AML risk practices and expectations to the OG and the AML Office to ensure a consistent understanding of these expectations.
Implement LOB / LE monitoring, performance metrics and processes to consolidate, interpret and report AML issues and emerging risks within OG.
Identify and interpret AML risk exposures, trends and early warning signs.
- Establish and monitor suitable KRIs/Risk Tolerance risk metrics to track AML related processes and controls.
- Perform standard and ad-hoc analyses and reporting.
- In conjunction with the Director, monitor material AML risk mitigation action plans to ensure they are implemented by the Operating Group to close identified gaps.
Participate on appropriate governance (project, strategy, leadership team) forums to ensure risk considerations are a key input into business strategy.
Build and maintain effective relationships with OG stakeholders as well as regulators and other partners
Knowledge of AML regulatory requirements
Knowledge of AML Risk Management Requirements
Expert knowledge of assigned Operating Group’s products and supporting business processes across the assigned LoB.
Expert knowledge in understanding of assigned Operating Group structure.
- Operating Group organization.
- Interrelationships and changes occurring within BMO enterprise.
- Policy framework, related procedures and control frameworks.
- Related risk frameworks and risk management practices.
Broad knowledge of assigned LoB and T&O business areas
Broad knowledge in monitoring techniques, quantitative techniques and audit methodology
Experience in roles requiring product and process management, implementation of governance and controls and risk management oversight.
Ability to influence others.
Highly developed relationship management, negotiation and leadership skills.
Strategic vision and planning ability.
Conceptualization, presentation and communication skills to effectively execute change.
Excellent change management skills.
Sound judgment and strong analytical skills to identify opportunities for enterprise collaboration.
Excellent communication skills in working with Senior Executives, Managers, Auditors, and Regulators.
Strong logic and data integration skills.
Strong critical thinking.
Ability to identify and affect appropriate risk governance and control mechanisms
We’re here to help
At BMO we have a shared purpose; we put the customer at the centre of everything we do – helping people is in our DNA. For 200 years we have thought about the future—the future of our customers, our communities and our people. We help our customers and our communities by working together, innovating and pushing boundaries to bring them our very best every day. Together we’re changing the way people think about a bank.
As a member of the BMO team you are valued, respected and heard, and you have more ways to grow and make an impact. We strive to help you make an impact from day one – for yourself and our customers. We’ll support you with the tools and resources you need to reach new milestones, as you help our customers reach theirs. From in-depth training and coaching, to manager support and network-building opportunities, we’ll help you gain valuable experience, and broaden your skillset.
To find out more visit us at https://bmocareers.com .
BMO is committed to an inclusive, equitable and accessible workplace. By learning from each other’s differences, we gain strength through our people and our perspectives. Accommodations are available on request for candidates taking part in all aspects of the selection process. To request accommodation, please contact your recruiter.
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