SVP Anti Bribery & Anti Corruption OfficerTitle: SVP Anti Bribery & Anti Corruption Officer
Location: North America-United States-New York-New York
Job Number: 00002H50
Responsible for enhancing and consolidating the HNAH Anti-Bribery & Anti-Corruption program to ensure that HNAH in the United States is in compliance with all aspects of the U.K. Anti-Bribery Act and the Foreign Corrupt Practices Act (FCPA"). Responsible for ongoing monitoring of the effectiveness of the firm's anti-bribery and anti-corruption program and escalation of enhancement needs, as well as for the enterprise-wide bribery and corruption risk assessment.
Assist with the development and delivery of targeted training related to anti-bribery and corruption issues.
Support the investigative due diligence process in assist HNAH in understanding the risks attendant to certain potential business relationships, such as mergers and acquisitions, joint ventures, and agent, distributor and other third-party relationships.
Impact on the Business
· Develop and maintain an enterprise-wide HNAH anti-bribery and anti-corruption program , including related risk assessment, compliance policies, procedures and training
· Stay up-to-date on anti-bribery and anti-corruption developments, both internal and external (regulatory, enforcement, best practice, industry)
· Develop and assist with the delivery of anti-bribery and anti-corruption training programs
· Review and assist with the update of policies, procedures and controls
· Lead the training and communication efforts
· Provide day to day compliance oversight with respect to gifts & entertainment requests escalated to Corporate Compliance, anti-bribery due diligence (e.g., M&A) including definition of record-keeping requirements and approvals
Customers / Stakeholders
· Work with the business lines, Legal Department and LCOs to ensure Anti-Bribery & Anti-Corruption Program and risks are understood and adequately integrated into both the Corporate Compliance and business line strategy
· Coordinate with other corporate compliance functions to ensure that bribery and corruption risks are effectively communicated and addressed
· Represent HNAH in working project meetings, committees, external association and consultant engagements that impact on HNAH's overall anti-bribery & corruption strategy
Leadership & Teamwork
· This role will have oversight for the day-to-day management of the HNAH Anti-Bribery & Anti-Corruption program by providing subject matter expertise to the HNAH lines of business and LCOs
Operational Effectiveness & Control
· This role will coordinate with the HNAH FIU and partner on investigations that may involve the proceeds of bribery and corruption
· This role will institute an ogoing program of continuous improvement that will review, recommend and assist in the implementation of plans, strategies and methodology to continuously upgrade HNAH's Anti-Bribery Program
· To discharge the accountabilities set out in the Legal and Compliance FIM by pro-actively assisting management in identifying and containing compliance risk, monitoring, reporting and certification, fostering a compliance culture and optimizing relationships with regulators
Major Challenges
· Current lack of a strong Compliance IT infrastructure across the HNAH franchise and lack of a centralized Policy and procedures for anti-bribery and anti-corruption
Role Context
· The position has a reporting relationship directly to the SVP, Enterprise Compliance
· This role will help ensure that the HNAH Anti-Bribery and Anti-Corruption Program continually adapts to changing needs and requirements through continuous self-improvement, effective and coordinated project management, and by pro-actively planning the utilization, deployment, sharing and leveraging of upgraded and/or new technologies, data, systems, methodology and techniques
· This role will partner with the Compliance Policy Office, the LCO Program Director and Compliance Technology office to coordinate the structure, organization, level of staffing and expertise required to maintain the Anti-Bribery Program and related business lines procedures across HNAH
Management of Risk
· Ensure employees apply compliance, operational risk controls in accordance with HSBC or regulatory standards and policies; and optimize relations with regulators by addressing any issues
· Promote an environment that supports diversity and reflects the HSBC brand
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
· To implement the Group compliance policy locally by containing compliance risk in liaison with the Global Head of Compliance, Global Compliance Officer, Area Compliance Officer or Local Compliance Officer, ensuring adequate compliance resources and training, fostering a compliance culture and optimizing relations with regulators
· Minimum of ten years proven financial services operations, compliance legal management experience or equivalent. Demonstrated knowledge and experience with Anti Bribery & Anti Corruption programs and regulatory requirements
· Minimum of a Bachelor's degree in business, related field or equivalent experience; Master's degree or JD preferred
· Strong managerial, communications, analytical, organizational, project management and planning skills
· Strong knowledge of assigned businesses, products, operations, systems and organization and full understanding of all significant regulatory compliance requirements applicable to all HNAH lines of business
· Proven ability to accomplish high-level objectives in the context of annual business and compliance plans
· Proficiency with personal computers and pertinent mainframe systems and software packages
Job: Legal & Compliance
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