Role Title: Manager, Global Markets Regulatory Compliance
New or Existing Role: Existing
- GBM Regulatory Compliance Risk Strategy (RCRS) is a global team which oversees Regulatory Compliance Risk through the design, implementation, embedding and management of the RC Risk Framework across Global Banking & Markets. GBM RCRS supports the ‘Global Head of GBM Regulatory Compliance’ and the ‘Head of Regulatory Compliance for Europe’ in overseeing and where appropriate challenging the Regulatory Compliance function in effectively discharging it’s Risk Steward Accountabilities as outlined by the Operational Risk Management Framework.
- The role is a critical forward looking management role, and stakeholder management is essential as the role holder will work closely with mutliple stakeholders including the RC senior leadership team, Group Risk Strategy, GBM Chief Control Office, Global Operational Risk (Op Risk), RC Regulatory Assurance (RCRA), Internal Audit and business line Control Officers across all regions.
- The individual will report to the Head of GBM & Europe Risk Strategy and may be required to support in the delivery of the following objectives:
- Supporting the delivery of global strategic initiatives, such as the design and roll-out of the Regulatory Compliance Rule Mapping solution, Issues Management; Regulatory Exams including the Department of Justice Deferred Prosecution Agreement and Federal Reserve Board Consent Order; GBM Conduct Programme, Non-Financial Risk Roadmap and others. The individual will support the Head of GBM Risk Strategy in understanding these various strategic initiatives, ensuring global consistency, identifying potential obstacles, regional regulatory expectations, overlap and efficiences, reporting on progress and providing senior RC management with a view on best practice;
- Implementation and oversight of the Trigger Events process, including gathering and analysis of Management Information to identify Current and Emerging Risks;
- Ongoing management of the GBM RC Risk strategy governance structure to ensure senior RC management are provided with accurate and timely reporting on top and emerging regulatory compliance risks and material changes to the GBM RC risk profile;
- Providing input to the Annual Compliance Plan and 1LOD/2LOD/3LOD testing plans to ensure resource and activities are appropriately linked to the GBM RC view of top and emerging risks;
- Providing training and ongoing support to the GBM RC function to ensure Risk Stewards fully understand and perform their role according to the Group Operational Risk Framework;
- Ongoing oversight of the Risk & Contol Assessment (RCA) process to ensure consistent interpretation and application of risks and controls across GBM RC (including the identification and escalation of any inconsistencies);
- Supporting other BAU deliverables such as the Operational Risk Annual Risk Scenario Analysis exercise, to ensure robust RC oversight and challenge and other activities as directed by the GBM Head of Risk Strategy;
- Assisting the Global Head of RCRS with ad-hoc tasks and projects as they arise.
Impact on Business
- To support the Business by providing specialist assistance as required;
- To proactively identify key emerging compliance risks across all RC categories and interface appropriately with other RC teams and senior management;
- To provide greater understanding of the potential impact and associated consequences of failing to manage significant new or emerging risks;
- To proactively work with the Business and Stakeholders to develop policies and procedures as required;
- To provide innovative and effective solutions based on SME knowledge to assist the Function; and
- Proposing, managing and tracking the resolution of subsequent risk management actions.
- Support the embedding of a globally consistent RCRS Operating model to provide actionable RC risk insight;
- Consolidation and analysis of risk information to identify RC risk insights for senior RC stakeholders to action;
- Implementation of tracking and oversight protocols to ensure action is taken, where required;
- Training, communication, refinement and full embedding of the ORF and new regulations across RC.
Supporting responsibilities / capabilities
- Providing input into the design of and implementing enhancements to RC risk framework components, managing the incorporation of RC requirements within the overall risk governance framework and strategy.
- Ongoing review of the RC Risk Appetite Framework for GBM.
- Overseeing the Consolidated Risk Report (CRR) and Risk Appetite reporting processes and providing RC risk analysis and commentary to senior RC management, as well as proposing, managing and tracking the resolution of subsequent risk management actions.
- Supporting the development and maintenance of the global regulatory inventory of rules for GBM.
Customers / Stakeholders
- Face key Business decision makers (including Risk Owners, Control Officers and Control owners) within the bank and ensure a clear and open channel of communication with management so information, questions, and concerns of HSBC can be directed to the proper stakeholders in a prompt and efficient manner;
- Engage with RC and the Functions on emerging themes and compliance risks that could impact them;
- Interact with and coordinate activity with RC and the Functions as required;
- Collaborate with RC policy owners on horizon risks that may impact business;
- Interact with and coordinate activity with Op Risk, RC Transformation Programme (RCTP) and Change Authority as required
- Deliver fair outcomes for our customers and ensure own conduct maintains the orderly and transparent operation of financial markets.
- Leadership & Teamwork
- Support development and communicate a clear vision for RCRS that is aligned to the overall HSBC vision, Values and goals, and inspires and engages people to create an inclusive, high performing, customer-centred culture;
- Lead, develop and motivate the leadership team to attract, retain and develop the capacity, capability and talent to provide for succession and ensure delivery of business objectives;
- Set expectations, share best practice and manage, monitor, coach and develop leaders and others to ensure that they maximise their performance, meet the required standards, and continuously develop their capabilities and experience; and
- Lead and encourage constructive cross-country and cross-business teamwork by demonstrating collaboration and matrix management in action and taking prompt action to address any activities and behaviours that are not consistent with HSBC's diversity policy and/or the best interests of the business and its customers.
Operational Effectiveness & Control
- Lead the continuing development, implementation and improvement of the processes, structures, capabilities, capacity and infrastructure needed to deliver agreed plans and targets, collaborating with colleagues to maximise end to end integration, effectiveness and efficiency;
- Establish and maintain a robust and efficient control environment to ensure good operational, financial and project management and compliance with HSBC policy and procedures, together with early identification and effective resolution or escalation of issues that arise;
- Lead the development, implementation and maintenance of management information, analysis and reporting framework that supports and informs timely and effective business management and decision making at all levels;
- Lead the implementation and oversight of policy and governance frameworks, procedures, practices and standards to ensure quality, effective risk management and regulatory compliance;
- Provide on-going consultation and SME advice on the regulatory environment;
- Implementing and upholding global standard processes;
- Undertake regular checks of Regional reporting to ensure this is being delivered to a high standard and in a globally consistent manner;
- Producing comprehensive MI; and
- Critically review MI to create meaningful assessments of both functional performance and business risk and produce suitable reporting.
Management of Risk
- The jobholder will ensure the fair treatment of our customers is at the heart of everything we do, both personally and as an organisation. This will be achieved by consistently displaying the behaviours that form part of the HSBC Values and culture and adhering to HSBC risk policies and procedures, including notification and escalation of any concerns and taking required action in relation to points raised by audit and/or external regulators.
- The jobholder is responsible for managing and mitigating operational risks in their day to day operations. In executing these responsibilities, the Group has adopted risk management and internal control structure referred to as the ‘Three Lines of Defence’. The jobholder should ensure they understand their position within the Three Lines of Defence, and act accordingly in line with operational risk policy, escalating in a timely manner where they are unsure of actions required.
- Through the implementation the Global AML, Sanctions and ABC Policies, supporting Guidance, and Line of Business Procedures the jobholder will make informed decisions in accordance with the core principles of HSBC's Financial Crime Risk Appetite.
- The jobholder has responsibility for overseeing and ensuring that operational risks are managed in accordance with the Group Standards Manual, Risk FIM, & relevant guidelines & standards. The jobholder should comply with the detailed expectations and responsibilities for their core role in operational risk management through ensuring all actions take account of operational risks, and through using the Operational Risk Management Framework appropriately to manage those risks.
This will be achieved by
- Continuously reassessing risks associated with the role and inherent in the business, taking account of changing economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new technology.
- Ensuring all actions take account of the likelihood of operational risk occurring, addressing areas of concern in conjunction with Risk and relevant line colleagues, and also by ensuring that actions resulting from points raised by internal or external audits, and external regulators, are correctly implemented in a timely fashion.
Observation of Internal Controls
- The jobholder will adhere to, and be able to demonstrate adherence to, internal controls and will implement the Group compliance policy by adhering to all relevant processes/procedures.
- The term ‘compliance’ embraces all relevant financial services laws, rules and codes with which the business has to comply. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators.
- RCRS is a recently formed team, so the role holder must be able to work comfortably within a fluid and developing framework.
- The role holder is expected to make decisions appropriate to their areas of responsibility and work openly and collaboratively with their line management and team colleagues. The role holder will interact with key stakeholder teams (internal and external to RC) at group level and with senior RC management as described above.
- The role holder must be determined and be able to engender the support of a number of senior executives across the three lines of defence, who may have their own conflicting local pressures. Against this background, the role holder must be able to drive through solutions to successful conclusion and to ensure that risks are being properly managed.
- The role holder will be engaged and should participate in the development of RC strategy and planning.
- HSBC operates in an increasingly complex and challenging regulatory environment. There is significant challenge in striking a balance between the demands of global regulators and the Group’s shareholders and customers.
- Global RC is experiencing a period of rapid and deep change impacting RC Risk and the structure and operation of the function itself. There are additional challenges from Op Risk transformation initiatives and implementation of efficiency programmes.
- Against this period of considerable regulatory change and development, and as regulators develop their own understanding of compliance risk management, the role holder must maintain a strong knowledge and understanding of regulatory development and the evolution of the compliance risk framework, risk appetite and risk assessment methodology.