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ING France, c’est la banque des particuliers (anciennement ING Direct) et la banque commerciale (ING Wholesale Banking).
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The Manager of FEC management and MLRO France is a member of the France Compliance Team and will be responsible for the oversight and monitoring of the implementation FEC related policies including Anti-
money Laundering, Anti-terrorist Financing, Customer Due Diligence, Export Trade Compliance, Proliferation Finance and Sanctions (including Ultra High Risk Countries).
Help translate enterprise wide FEC policies and procedures to local policies, procedures and processes. He / she will act as a subject matter expert providing guidance and advice to the business and compliance officers regarding the provisions and regulatory requirements in these areas.
He / she is responsible for driving FEC compliance through the implementation of manual and automated processes / procedures and close cooperation with the business units within France and key stakeholders in- and outside ING..
Provide leadership and direction to the FEC team
Support, coach and mentor FEC team members
Responsible for setting, writing and regular maintenance of Financial Economic Crime standards used within the FR business.
Provide support and advice for all FEC related issues to senior management within FR and the different business.
Work closely with Compliance Officers to ensure that the business units meet the requirements set by the policies and applicable laws, rules and regulations in the area of FEC
Liaise with regulators, industry bodies and peers to ensure that FEC policies meet regulator and industry standards.
Provide advice to local Compliance on FEC related transactions and contracts.
Work closely with Head of Compliance France, Legal and the Global Head of FEC / AML & Sanctions of ING Bank Compliance Risk Management (BCRM -
at HQ level) to ensure that implementation of (global) policies and complex waiver decisions meet regulatory requirements.
Oversee the ongoing FEC operations to ensure the policy and systems meet business requirements, meet regulator and industry standards and drive required changes to ensure compliance.
Attend NFRC for FEC related issues.
Global Head of FEC / AML & Sanction of ING Bank
BCRM FEC Team.
Compliance FR Team.
The network of MLRO’s / Head of FEC of the different divisions / business units of ING Bank worldwide.
Senior management of the business in France.
Senior management and other staff of other risk departments (e.g. ORM, Legal) and CAS
Relevant external stakeholders (e.g. regulators ACPR, AMF)
Knowledge and Skill Requirements
Academic degree in a relevant discipline with recognised compliance accreditation.
8 to 10 years in the financial services industry with at least 3 to 5 years in a similar position within Compliance.
Strong understanding and experience in dealing with FEC, Anti-Money Laundering, Sanctions etc controls and other related legislations with ability to identify applicability to a wide range of businesses.
Ability to provide timely and comprehensive recommendations to mitigate FEC risks.
Experience in establishing compliance policies and procedures in a cross border environment.
Excellent communication and presentation skills fluent in French and English language.
Strong inter-personal skills and the ability to communicate difficult and unpopular messages.
Strong coaching skills are important.
Ability to think at both strategic and operational levels.
Persuasiveness : the ability to influence the Business to implement the FEC requirements.
Problem Analysis and Analytical Problem solver, good judgment, can make up his mind;
Organisational Sensitivity / Empathy : the ability to grasp what moves clients and the capacity to professionally adapt to their demands.
Team and Individual) Leadership : the ability to translate strategy into policy in the field of compliance and effectively steers and directs a team and creates and maintains partnerships to achieve set goals.
Flexibility : the ability to adapt to various situations or caused by the market. And applies different behavioural styles in order to realize goals.
Decisive; committed by expressing his / her opinion.
The critical competencies are essential for the position. However, achievement orientation, planning, organising, listening, sensitivity and capability to build networks are also crucial and need to be part of the personality of the ideal candidate