Head of Enhanced Due Diligence

Barclays Overview

Barclays is a British universal bank. We are diversified by business, by different types of customers and clients, and by geography. Our businesses include consumer banking and payments operations around the world, as well as a top-tier, full service, global corporate and investment bank, all of which are supported by our service company which provides technology, operations and functional services across the Group.

It is the policy of Barclays to ensure equal employment opportunity without discrimination or harassment on the basis of race,  colour, creed, religion, national origin, alienage or citizenship status, age, sex, sexual orientation, gender identity or expression, marital or domestic/civil partnership status, disability, veteran status, genetic information, or any other basis protected by law.

Dynamic working gives everyone at Barclays the opportunity to integrate professional and personal lives, if you have a need for flexibility then please discuss this with the hiring manager.

We are an equal opportunity employer and we are opposed to discrimination on any grounds.

About Financial Crime Execution

The CIB Financial Crime Execution (CIB FCE) team manages all elements of the financial crime agenda within the Front Office. The team works across a global footprint and is responsible for driving the financial crime goals and objectives of the bank within the relevant business units, working on helping to mitigate the risks of products and services being abused for the purposes of money laundering, terrorism financing, or other financial crime.

The CIB FCE remit covers Investment Banking, Global Markets, UK Corporate Banking as well as International Corporate Banking within Investment Banking. The emphasis is on execution of the policies and standards put in place by the Financial Crime Compliance team within the second line of defence. Responsibilities include the day to day management of the financial crime agenda as it impacts the client lifecycle (onboarding, review and exit decisions) as well as oversight on behalf of the responsible executive of the day to day controls and execution of risk appetite, with particular focus on good governance of high risk sector clients and special customer types.

CIB FCE also ensure good oversight on driving continuous process improvement in the execution of risk control activities, which includes ensuring that relevant KRIs are met and working closely with colleagues in Financial Crime Compliance and in BX to manage the whole lifecycle of the customer’s interaction with the bank.

CIB FCE is made of up four distinct teams: the Risk Assessment Unit, the Enhanced Due Diligence (EDD) team, Governance & Control and Business Implementation. These teams are responsible for various elements of the lifecycle, such as subjective decision making on financial crime processes as impacts individual clients (NOT exceptions to policy), the management of Client and Colleague experience, building towards Barclays being ‘best in class’ for KYC and onboarding experience and the oversight of financial crime training for all front line staff and management of communications for the front line relating to the financial crime agenda.

About EDD Team

The EDD team is responsible for the Enhanced Due Diligence reviews of ICB & Corporate Banking clients focusing on Correspondent Banking, MSBs/Fintech, On-Line Gaming, Politically Exposed Persons (PEP), clients involved in processing Cash and other High Risk Sectors.

The EDD team sits within the first line of defence but acts independently of the coverage teams. Responsibilities include undertaking EDD reviews for refresh and on-boarding of clients involved in the sectors detailed above using internal, external and public source tools to understand the AML/Terrorist Financing/Sanctions/ABC risk profile of the clients.

EDD Managers are required to understanding of the risks of their sectors along with geographic risks and risks in the products clients have access to. The team act as Subject Matter Experts providing Specialist knowledge and Technical understanding to the business.

EDD Managers undertake face to face meetings at client premises as well as telephone calls with clients. Stakeholder engagement is with C Suite level management including MLROs and Head of Compliance to review and discuss client responses to our questionnaires and any areas of concern identified through Internal and External research. The reports created out of these reviews will highlight the impacts of a client not applying globally recognised AML, Sanctions & CTF standards.

The team produce EDD Reports summarising reviews, identifying gaps in regulatory policy and material risks to the Bank. These reports are fundamental to assist senior management in making decisions to on-board, retain or exit clients. These are presented to Relationship Directors for review and then presented to the appropriate review forum by the EDD Manager for a decision to be made on whether to on-board, refresh or exit the relationship. The forums consist of senior management across the bank from Coverage, FinCrime, Business Management, Legal and Compliance.

The team is primarily based in London with resources in Birmingham, Hong Kong, Singapore, New York and Dubai. Clients are based globally and EDD Managers are expected to travel to meet clients either on their own or with the Relationship Director.

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Overall purpose of role

• The role holder will set the EDD agenda and direct the team, delivering EDD for high risk clients across ICB and Corporate Bank, ensuring consistency across the business globally.  This is a high profile role: the role holder will operate at a senior level, and significant financial and reputation risks exist if unsound judgement is applied.
• The current focus of the EDD strategy is managing EDD for the Correspondent Banking, Fintech/MSB, On-Line Gaming and PEP sectors.
• Delivering EDD processes for new segments such as Cash & Precious Metals and eMarketplaces will be a key deliverable of the role holder.
• Managing both internal and external audit reviews and discussions with regulators and other oversight functions will be a key part of the role.
• Identifying and delivering change to either improve the risk management and/or efficiency of the EDD process will be a key on-going objective of the role.

Key Accountabilities

Team Leadership and structure - Build and manage a global team, supporting and challenging team members to ensure they have the ability to deliver quality and consistently to target, whilst providing a positive client and colleague experience. Lead the overall strategy and direction of EDD for ICB and Corporate Bank.

• Ensure that direct reports are well managed, with challenging objectives, adequate support and timely interventions as necessary.
• Ensure that team members are well engaged, with appropriate 121s, information sharing and clarity of role boundaries.

Complex client situations/escalations and senior case review

With ownership for delivery of EDD, responsible for oversight of all EDD deliverables. This will include undertaking senior case reviews and making quality and consistency assessments.

• In managing complex situations and/or escalations, proactively conduct client meetings, engage relationship teams for resolution and show diplomacy.
• The role holder will need the necessary gravitas and skill to represent Barclays at a senior level and, during difficult conversations, exert influence over leaders at Barclays and other institutions. This will include requesting and scrutinising sensitive client information, whilst balancing the need for a positive client experience. The role holder will be required to liaise directly with CEOs/ Head of AML/ Head of Compliance as necessary. 
• Apply sound judgement to complex client situations/escalations given the information available and accounting for the wider client context and external environment.
• Manage and own the EDD processes and procedures, and act as the Coverage escalation point for EDD.

Key Performance indicators

• Delivery of EDD strategy objectives achieved across Customer, Company and Colleague metrics.
• No adverse regulatory findings.
• Satisfactory Internal Audit, Financial Crime Assurance Reviews and other internal/external assessments of the function’s activities.
• Quality of client information improved.
• Achievement of personal objectives, as agreed with line manager.
• Adherence to the Values, embedding those behaviours amongst the wider team.
• Demonstrating a Barclays Mindset in delivery of objectives.

Stakeholder Management and Leadership

• • Ensure effective relationship developed with Financial Crime Compliance, TC01, Product and other key partners to ensure smooth delivery of objectives.
  • Ensure Coverage stakeholders understand and acknowledge the strategy and TOM for EDD, working to expand the team’s scope to take ownership of EDD for all high risk clients and to improve EDD delivery. Drive team members to own EDD design and process improvement.
  • Provide senior management with MI and proactively balance the load of the team taking refresh cycles into consideration
  • Take a forward looking  view of global regulatory requirements, emerging product and client risks /issues with a view to improve EDD design and processes.

Decision-making and Problem Solving

The role holder is required to use their skills and knowledge to evaluate information gathered from different sources and make sound recommendations.

They will be working across multiple client types and different business areas, so must be able to evaluate information and data from different sources and understand the impact of decisions across these multiple areas.

The role holder is required to be able to work on their own using their initiative and knowledge and skills to produce a comprehensive recommendation whilst leading the team and driving the workflow inline with Internal Standards and External Regulations.

Risk and Control Objective [This section is mandatory for all role profiles and must not be deleted]

Ensure that all activities and duties are carried out in full compliance with regulatory requirements, Enterprise Wide Risk Management Framework and internal Barclays Policies and Policy Standards.

Person Specification

• A strong proven leader with the ability to build and manage diverse teams
• Driven, with a focus on risk based client-driven solutions, strategy setting and decision making
• Demonstrates gravitas with the ability to manage and influence other parts of the bank (such as Financial Crime and KYC Ops), build consensus and navigate difficult conversations to reach positive outcomes, thus ensuring best client and colleague experience 
• Enquiring and determined with the ability to drive a culture of questioning and probing within the team
• Demonstrates effective planning and organising with an ability to execute at pace
• Team player and relationship builder, with a strong ability to collaborate and effect positive change

Essential Skills/Basic Qualifications:

• Experienced in managing global teams with complex deliverables in dynamic banking environments – in particular teams that have been required to balance the need to meet regulatory and risk management requirements along with excellent client and colleague engagement
• Detailed understanding of Banking Industry - key providers, client groups and products, especially focussed on AML/KYC processes and impact for clients and colleagues
• Excellent communication skills and impact
• Full understanding of economic, market and customer trends and development
• Comprehensive business knowledge - in order to understand the markets in which the relationship teams’ customers operate and the business issues they are likely to face
• Control environment - including risk management and related processes

Desirable skills/Preferred Qualifications:

• • Degree or equivalent level of education
  • Relevant AML/CTF or ABC qualifications i.e. ICA or ACAMs

Purpose and Values

Barclays has a single cross-business Purpose for Barclays and five core Values which underpin it.

Our Purpose is helping people achieve their ambitions in the right way. Put simply this is the answer to the question ‘What is Barclays for?’ and it should guide our every action as employees.

Respect

We harness the power of diversity and inclusion in our business, trust those we work with, and value everyone's contribution.

Integrity

We operate with honesty, transparency and fairness in all we do.

Service

We act with empathy and humility, putting the people and businesses we serve at the centre of what we do.

Excellence

We champion innovation, and use our energy, expertise and resources to make a positive difference..

Stewardship

We prize sustainability, and are passionate about leaving things better than we found them.