The primary role of the Anti-Money Laundering and Counter Terrorist Financing (AML/CTF) Regulated Business Lead is to lead Accenture’s AML Centre of Excellence (CoE) and be responsible for the oversight of the local Anti-Money Laundering Compliance Officers (AMLCOs) across the Globe. The role will provide independent challenge, steer and support to the AMLCOs, who are in turn responsible for the day-to-day operation of the AML regulated programs in their respective legal entities.
The AML/CTF Regulated Business Lead is responsible for the strategic design and updating of consistent Global AML/CTF standards including by defining and disseminating common processes, templates and frameworks by which the AMLCOs will operate. They will also share best practices amongst the global AMLCO network and drive accountability of the AMLCOs in the operation of each local AML programme. They will be responsible for managing the regulatory perimeter and establishing new AML programmes where Accenture business is identified as falling within the regulated AML space.
The AML/CTF Regulated Business Lead will report to the Global Director for Trade, AML and CTF.
Scope of Responsibilities:
The AML/CTF Regulated Business Lead will be expected to perform the following activities:
Participate and execute key decisions for the creation of new AML/CTF Regulated Programmes or the dissolution of these programmes as required in relation to new business expansions globally (e.g. crypto) and/or expansion of licensed/regulated activities (e.g. insurance/payment services);
Defining duties for, appointing/hiring of and onboarding appropriate individuals to fulfil the AMLCO and AML Delegate roles in each of Accenture’s regulated entities subject to local AML laws and regulations.
Providing first level approval for all local AML/CTF policies and procedures for regulated entities prior to formal local Board or Senior Leadership final approval.
Acting as escalation point for remedial action to address findings identified through LCM monitoring of the red flag escalation and KYC processes.
Ensuring the implementation of remedial action/resolving gaps to address findings/outcomes of formal reviews (including, but not limited to, the global AML programme audit, Company Risk Assessment and external counsel reviews).
Performing periodic desk reviews in the local market of each AMLCO to maintain oversight over the operation of each local AML programme and identify any challenges to facilitate timely resolution.
Regularly monitoring for regulatory/legal updates and tracking changes both locally and globally across AML/CTF and other relevant regulation, with support from selected local counsel.
The AML/CTF Regulated Business Lead will also liaise with local AMLCOs to ensure relevant updates are appropriately identified, evaluated and factored into each AMLCO’s respective programme.
Acting as a point of consultation and/or support for the AML Programme Director and Global AML 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 Programme Risk Assessment and controls evaluations;
- Definition of AML Risk Aids and AML Handbooks;
- Practical prospective business venture support, such as pertaining to expansion of existing scope of services or mergers/acquisitions;
- Global AML policies and procedures;
- Contracts and RFPs containing AML elements;
- Definition of predicate offences and red flags applicable to Accenture’s global operating footprint;
- CBT requirements for higher risk employees in non-AML regulated areas of Accenture’s business model; and
- Global internal or external AML programme reviews.
Engaging with regulatory bodies related to any regulatory investigations, remediations or other matters. Working with auditors (internal and external) with regard to the AML programme and monitoring implementation of audit points or regulatory findings Contributing to thought leadership articles or regulatory consultations related to AML
Working in conjunction with the local AMLCOs, designing Accenture’s AML CBT programme. Designing and delivering:
- Tailored AML/CTF training required to be undertaken by AMLCOs and their Deputies/Delegates; and
- Local relevant awareness-raising and issue spotting initiatives, identified in conjunction with input from local AMLCOs as a result of internal or external triggers.
Setting the standard for and ensuring the completion of any agreed formal AML accreditation/certification programs by the AMLCOs (and their Delegate, if considered necessary).
Reports to: the AML Programme Director
Relationships: Global AML Team, local AMLCOs for each legal entity, AML CoE, KYC Team, LCM Team.