The role is responsible for managing and overseeing customer due diligence, customer risk assessment, sanctions screening, enhanced due diligence, ongoing monitoring, and financial crime risk management activities across the customer lifecycle.
The role ensures the effective execution of AML and customer due diligence controls, while supporting ongoing monitoring, governance, analytics, quality assurance, and continuous improvement initiatives to strengthen the organization's financial crime risk management framework.
The role combines operational management and risk oversight responsibilities and is accountable for ensuring compliance with regulatory requirements, internal policies, and risk management standards while supporting business operations and maintaining an effective control environment.
The role also leads the assessment and determination of internal policy replacements, including the recommendation and documentation of financial consequences in accordance with company guidelines.
1. Customer Due Diligence & Risk Assessment
- Manage the investigation, review, and disposition of customer due diligence, sanctions screening, and customer risk rating alerts.
- Oversee the conduct of customer risk assessments, customer due diligence (CDD) and enhanced due diligence (EDD) reviews.
- Ensure appropriate identification, assessment, escalation, and mitigation of financial crime risks.
- Review and assess higher-risk customers such as complex ownership structures, and politically exposed person (PEP) relationships.
- Support risk-based decision making through the provision of due diligence findings and recommendations.
- Maintain oversight of customer due diligence activities throughout the customer lifecycle.
2. Customer Onboarding & Policy Servicing Support
- Oversee CDD, screening, customer risk rating, FATCA, CRS, and EDD activities supporting new business, onboarding, and policy servicing processes.
- Ensure timely review and disposition of AML-related alerts and risk assessment activities.
- Manage triggering event reviews arising from customer lifecycle events, policy servicing activities, and material changes in customer risk profiles.
- Escalate significant AML, sanctions, fraud, or financial crime concerns to appropriate governance forums and stakeholders.
3. Policy Replacement Reviews
- Review and assess policy transactions to identify potential policy replacement cases based on established criteria and risk indicators.
- Determine and document appropriate case classifications, including policy replacement, non-replacement, or potential inappropriate replacement.
- Ensure assessments are consistent with regulatory requirements, company policies, and governance standards.
- Maintain complete, accurate, and audit-defensible records supporting assessment outcomes and decisions.
- Endorse validated cases for downstream processing and escalate complex, high-risk, or exceptional cases for further review and approval.
4. Annual Reviews & Ongoing Due Diligence
- Manage annual reviews of high-risk customers and other periodic customer reviews.
- Ensure timely completion of customer refresh and ongoing due diligence requirements.
- Monitor remediation activities arising from customer reviews and control assessments.
- Review the adequacy and effectiveness of ongoing due diligence controls and processes.
5. Quality Assurance & Control Effectiveness
- Conduct and oversee quality assurance reviews to assess compliance with regulatory requirements, policies, procedures, and operational standards.
- Perform thematic reviews, control assessments, and root cause analyses to identify areas for improvement.
- Monitor the effectiveness of AML, sanctions screening, customer due diligence, and monitoring controls.
- Recommend and implement corrective and preventive actions to address identified issues and control gaps.
6. Ongoing Monitoring & Transaction Monitoring
- Oversee ongoing name screening and customer risk rating monitoring activities.
- Manage transaction monitoring investigations and alert review processes.
- Monitor customer risk profile changes and emerging financial crime risks.
- Ensure timely identification, investigation, and escalation of unusual or potentially suspicious activities.
- Support the enhancement of monitoring methodologies, rules, and control effectiveness.
7. Risk Analytics, Reporting & Governance
- Prepare and review management information, dashboards, key risk indicators (KRIs), and operational metrics.
- Analyze trends, volumes, risk indicators, and operational performance to support risk management and decision-making.
- Develop reports and presentations for management committees, governance forums, regulators, and internal stakeholders.
- Support risk assessments, governance activities, and reporting requirements across AML and financial crime risk management programs.
8. Data Governance & System Controls
- Oversee the maintenance and management of customer risk data, beneficial ownership information, and AML system records.
- Monitor AML system exception reports, data quality issues, and control deficiencies.
- Coordinate data remediation activities and process improvements to enhance data integrity and control effectiveness.
- Support implementation and optimization of AML systems, tools, and automation initiatives.
9. Audit, Regulatory & Project Management
- Coordinate responses to internal audit, external audit, regulatory examinations, and quality assurance reviews.
- Manage remediation activities and track closure of audit findings, management action plans, and regulatory commitments.
- Lead and support AML-related projects, process improvement initiatives, and transformation activities.
- Participate in policy, procedure, and framework development to strengthen the overall AML control environment.
- Support organizational readiness for regulatory changes, new products, new channels, and emerging financial crime risks.
10. Technical Leadership & Stakeholder Management
- Provide technical guidance and subject matter expertise on customer due diligence, customer risk assessment, sanctions screening, AML monitoring, and financial crime risk management.
- Support the resolution of complex, high-risk, and escalated cases, ensuring consistent application of policies and controls.
- Promote knowledge sharing, capability development, and continuous improvement across the function.
- Collaborate with Operations, Compliance, Risk, Legal, Claims, Underwriting, Technology, and other stakeholders to support the implementation of AML controls.
Job Requirements:
- Bachelor's degree in Finance, Accounting, Business, Economics, Risk Management, or a related discipline
- Preferably with relevant certifications such as:
a. CAMS (Certified Anti-Money Laundering Specialist)
b. ICA (International Compliance Association) certifications
- 8–12+ years of progressive experience in
o AML / Financial Crime Operations
o Customer Due Diligence / Enhanced Due Diligence
o AML Transaction Monitoring and Screening
- Experience conducting investigations involving high-risk customers, PEPs, adverse media, and complex ownership structures.
- Knowledge of AML, sanctions, FATCA/CRS, and related regulatory requirements.
- Experience in quality assurance, audit and regulatory remediation, risk analytics, management reporting, and process improvement initiatives.
- Proficiency in AML systems, screening platforms, case management tools, and data analytics solutions.
- Experience working within a regulated financial services environment, preferably in insurance, banking, wealth management, or fintech.
