Manager - Digital Assets Transaction Monitoring

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Compliance is an independent function at ADCB which takes an active approach to risk management and monitoring, ensuring the Bank complies with applicable laws, regulations, rules and market standards. The Group creates, implements and monitors policies and procedures designed to prevent or detect financial crime and any compliance breaches of the Bank, its employees and clients. It also monitors and measures the impact of conduct risk and compliance on the Bank’s risk appetite and profile.

• To manage complex transaction monitoring investigations, provide AML expertise and support regulatory compliance initiatives in order to mitigate financial crime risks and enhance operational controls including Digital Assets, Custody Services, Client Money Accounts covering both on-chain and off-chain (fiat) transaction flows.
• To assess industry standards locally and internationally to build and implement detailed procedures, policies, compliance frameworks, management reporting tools, monitoring infrastructure in order to complete due diligence on new and referred client on-boarding, to perform routine and periodic monitoring of on-chain transactional activity and screening of wallets to rule out money laundering/terrorist financing/sanctions risks, having oversight of Travel Rule adherence, performing investigations and reporting unusual/suspicious activities to relevant Regulators, in order to comply with regulatory requirements and mitigate risk exposure for the ADCB Group.
• Review account opening processes and Know Your Customer (KYC) documentation, having oversight and control of client due diligence, factoring Anti Money Laundering and Counter Terrorism Financing (AML/CFT) and sanctions risks, liaising with business units and vigilance and control team to ensure a robust KYC process.
• Document on-boarding decisions for reviewed clients, providing advisory for sanctions matches referred by operations and business units and provide sign off for account opening for increased risk and Politically Exposed Persons (PEP) customers to ensure compliance with regulatory requirements.
• Conduct risk assessments and issue advisory/take decisions on new and existing account opening requests, making decisions on the risk assessment (increased, PEP, neutral, un-acceptable risks) of all relationships to ensure compliance with regulatory requirements.
• Support line manager in developing scope of periodic and thematic reviews for all clients, liaising with business unit to ensure the review is completed in a timely manner and is in line with regulatory requirements.
• Review system generated alerts against customer data, investigating for potential Money Laundering and Financing Terrorism (ML/FT)/sanctions risks, collect documentary proof, build/maintain case files for transactions and customers deemed suspicious to ensure all required actions are taken. Update relevant Management Information Systems (MIS) to ensure accurate tracking and record keeping.
• Have oversight of post investigative actions; including update internal watch-lists, identifying tainted/blacklisted names/wallets and monitoring that the required actions are taken in order to fulfil regulatory requirements and avoid penalties.
• Support the Head of Digital Assets Compliance, Group Money Laundering Reporting Officer (GMLRO) and Deputy MLRO by reviewing, reporting and tracking of the Suspicious Transaction Reports (STR) and Suspicious Activity Reports (SAR) filed as an outcome of investigations performed to ensure accuracy of data reported.
• Maintain a track of actions communicated by/to all relevant Regulatory authorities to ensure all actions are followed through to completion.
• Support with addressing queries from the Regulator(s) and Law Enforcement Authorities relating to ML/FT and sanctions matters, including freezing of Assets and blocking of accounts, responding to and raising Requests for Information (RFIs) from other Institutions, and any other required reporting requirements to ensure all actions are completed within agreed Turnaround Times (TATs).
• Determine exit strategy for flagged customers, and follow through on closure of accounts/wallets, reporting to Regulator(s) to ensure effective closure of accounts/wallets and to mitigate AML, KYC and sanctions risks.
• Assess, design and review outcomes for parameter changes specific to client on-boarding, AML and Sanctions systems specific to Client Money Accounts, Digital Assets and Custody Services. Develop comprehensive user requirements and test cases, conduct testing for automated solutions, managing the identified fixes to ensure system is working effectively. Support and manage projects arising from regulatory changes to ensure timely…