The role of the Anti-Money Laundering Center of Excellence Counsel (AML COE Counsel) is to support the AML/CTF Regulated Business Lead as well as the local AML Compliance Officers (AMLCOs) (where required) in the exercise of their duties. The role will provide ongoing support to ensure successful day-to-day operation of the AML regulated programs in the respective Accenture companies (both regulated and unregulated).
The AML COE Counsel will also foster consistency amongst the local AML programs executed by the AMLCOs by ensuring common standards, practices and tools (such as templates and framework outlines) against which the AMLCOs will operate.
The AML COE Counsel will report and be directly accountable to the AML/CTF Regulated Business Lead and not the local AMLCOs.
Scope of Responsibilities:
The AML COE Counsel will be expected to perform the following activities:
- Providing support to the AML Program Director and AML/CTF Regulated Business Lead in appointing and onboarding appropriate individuals to fulfil the AMLCO and AMLCO Delegate roles in each of Accenture’s AML regulated entities (Local Regulated Companies).
- Supporting the creation, finalization and adoption of tools (such as templates and framework outlines) as well as the provision of guidance/consultative advice and oversight by the AML/CTF Regulated Business Lead to the local AMLCOs to enable them to carry out their duties relating to:
- Legal entity board reporting
- Company Risk Assessment
- Local AML-related policies and procedures
- Regulatory/Legal change tracking
- Core AML process (such as Know Your Customer (KYC) and red flag escalations)
- Responding to local audits, regulatory requests or inspections
- Local AML Program reviews (such as internal or external AML program reviews, annual external counsel AML program review and Legal Compliance Monitoring (LCM) Team monitoring of red flags and KYC, etc)
- Deployment of Accenture’s computer based training (CBT) program and other relevant local training/awareness initiatives, including proactively working to update
- Supporting the AML/CTF Regulated Business Lead and the AMLCOs in approving all local AML/CTF policies and procedures for Local Regulated Companies designed by the local AMLCOs.
- Providing necessary support to the AML/CTF Regulated Business Lead and the KYC Manager in defining KYC requirements to be adhered to by local AMLCOs in their capacity as executors of the AML framework in their Local Regulated Company.
- Supporting the AML/CTF Regulated Business Lead, and local AMLCO in the Local Regulated Companies, as required in the monitoring for regulatory/legal updates, tracking changes globally and impact assessment of the same with regards to both the Local Regulated Companies and Accenture’s unregulated business.
- Acting as a point of support and/or consultation to the AML/CTF Regulated Business Lead in defining and operating the process to establish and/or dissolve local companies as required as a result of changes to external factors (such as regulatory/legal updates) and internal factors (such as changes to Accenture’s overall business strategy).
- Supporting the design of the Accenture’s computer based training (CBT) program. The AML COE Counsel will provide support to the AML/CTF Regulated Business Lead and local AMLCO to help determine the audience, specifications and content for CBT as needed for both Local Regulated Companies and Accenture’s unregulated business.
- Supporting the AML/CTF Regulated Business Lead as well as local AMLCOs in designing and delivery of: Tailored AML/CTF training required to be undertaken by AMLCOs and their Deputies/Delegates, Local relevant awareness-raising and issue spotting initiatives, identified as a result of internal or external triggers
- Providing support to the AML/CTF Regulated Business Lead, where required, in analyzing the outcomes and implementing remedial action to address findings identified through LCM monitoring of the red flags and KYC processes, etc.
- Supporting the implementation of remedial action/resolving gaps to address findings/outcomes of formal reviews (including, but not limited to, the global AML program audit, Local Regulated Company (as well as the Global) Risk Assessment and external counsel reviews).
- Acting as a point of support and/or consultation for the AML Program Director and Global AML/KYC Team as required to provide input into global AML-related initiatives, including (but not limited to):
- Global Accenture Leadership and/or Board reporting
- Global AML Program Risk Assessment and controls evaluations
- Global AML policies and procedures
- Definition of predicate offences and red flags applicable to Accenture’s global operating footprint
- Global internal or external AML program reviews
- Reports to: Global AML/CTF Regulated Business CoE Lead
- Primary Relationships: Global AML Team, local AMLCOs for each Local Regulated Company, AML COE, AML Program Director, Policies Team, GCC Team, E&C Teams, Legal Compliance Monitoring Team, Legal Training Team, Business, PMI, V&A