• Regional leadership of the Legal & Compliance (L&C) teams supporting CIC in Africa. Support the Regional Head of L&C in ensuring appropriate legal and regulatory advice, training, risk assessment, monitoring and L&C decisions on CIC-related matters.
• Ensure close links with the central CIC L&C team, raising CIC-related issues, including material transactions, conduct/fair accountability issues, people issues and business feedback. Work with the central team to deliver global initiatives to the region.
• Maintain close relationships with CIC business heads in Africa, and assist the Regional Head of L&C, FCC, Control Room and L&C product teams to interface with and support such stakeholders.
• Support the Regional Head of L&C in promoting, leading and managing the culture and practice of organisational compliance with legal and compliance standards (including conducting business within legal and regulatory requirements, and to high ethical standards) within CIC and embed a Here for good culture and the Group Code of Conduct.
• Support Product L&C in delivering products to the regional CIC portfolio in an appropriate and compliant manner, promoting the culture and practice of organisational compliance and global standards, while managing any local requirements.
• Establish close links with colleagues leading other Client segments to achieve common platforms and work plans, implementing a One Bank approach to covering all Clients, particularly the emerging Commercial Clients segment.
• Support Heads, L&C CIC in delivery of a programme designed to increase awareness throughout the L&C function of business strategy, together areas of focus specific to CIC such as Offshore Booking Locations, adherence to single borrower limit and large exposure reporting requirements, balance sheet and capital efficiency, GSAM activity, representative office governance and reputational risk around client types generally.People and Talent
Support the Regional Head, L&C to:
• Ensure the L&C teams supporting CIC in Africa are adequately resourced and staffed by an appropriate number of competent staff sufficiently independent to perform duties objectively, to support sustainable business growth and address legal and compliance risks.
• Develop and implement strategy in the areas of resourcing, talent development, performance management, learning and development and engagement for L&C CIC in Africa.
• Actively engage relevant stakeholders (business product/segment, country teams, regulators, other infrastructure and governance functions, legal and compliance colleagues) to obtain continuous feedback on L&C CIC team performance and to strategize/prioritize tasks for the L&C risk management framework. Drive the import of best practice and lessons learned across the network especially in relation to legal/regulatory risks and compliance with relevant regulations and internal policies/procedures
• Play a core role in relevant fair accountability reviews, and provide input at business, function, country and individual level as appropriate, on regulatory and conduct matters which should have a bearing on remuneration pools or individual bonuses (for senior staff) in CIC
Business Partner and Independent Guardian
1. Business / Product Advisory
• Support the Regional Head, L&C to oversee provision of tailored transactional advice by L&C teams supporting CIC. Assist L&C Financial Markets, Transaction Banking and Corporate Finance product heads to gather and manage relevant stakeholders to ensure the delivery of an appropriately calibrated L&C solution.
• Take ownership of client documentation in Africa and drive consistency of execution, including ensuring that client documentation templates used in regions align to global templates as far as possible and deviations are strictly necessary under local law, regulations or practice. Own accountability for delivery of CIC client documentation, particularly for more important clients
• Take direction from Head, Legal, CIC in relation to implementing global standards and initiatives, including the Bank’s position on departures from standard clauses, and applying a consistent approach to issues management
• For Global Corporate (GC) clients where the client head office and Group Account Manager (GAM) are in the region, take global ownership of client documentation execution for that client, including making sure agreed position with the client is consistent with global standards.
• Support the Regional Head, L&C to oversee LDU and drive operational efficiencies/improvements where possible and to lead second line risk control ownership of legal risk in LDU’s processes for the region.
• Support the CIC centres of excellence in driving improvements to documentation processes.
• Support the Regional Head, L&C to ensure CIC teams in Africa are aware of and in compliance with current relevant laws and regulations. Ensure proactive and timely identification, assessment, advice and dissemination of evolving legal and regulatory changes/practices and associated risks across CIC business teams, and proactive engagement in regulatory reform.
• Support the Regional Head, L&C to ensure appropriate application into CIC teams of the L&C aspects of the infrastructure framework for cross-border and onshore/offshore transactional support and control.
• Assist as needed Country and Regional L&C in maintaining appropriate relationships with regulators in Africa, in particular in connection with CIC business and strategy.
2. Risk Framework and Monitoring
Support the Regional Head, L&C to:
• ensure the development and implementation of an appropriate risk based CIC L&C risk management framework and systems/controls for products in the CIC business in Africa – encompassing anticipatory risk identification, mitigation and assessment, training, monitoring and product/business advice, including client selection/de-risking and (in close collaboration with FCC teams) in relation to financial crime risk.
• Maintain effective processes to assure the CIC L&C product- and conduct-related policies and standards are effectively implemented across the CIC business in Africa and all its staff (in close coordination with the relevant business heads, CEOs, COOs and PGCs), and provide support to senior management to ensure that they establish and monitor appropriate arrangements for meeting legal and regulatory obligations, maintain high standards of conduct and avoid conflicts of interest in accordance with internal policies
• in collaboration with the Regional Compliance Monitoring Managers and Heads, Central CIC L&C, ensure that local risks associated with the CIC business in Africa are appropriately reflected in Country risk assessments, with CMRs established where necessary . Ensure global standards are understood and implemented in CIC locally, with any identified exceptions, or need for more/less stringent standards escalated to Central CIC L&C for joint decision-making.
3. Policies and Procedures
Support the Regional Head, L&C to:
• establish and maintain effective processes (including training, advice and support) to ensure that policies, procedures and standards to address legal and compliance risks are effectively implemented across CIC business teams throughout the region via early socialization with stakeholders in procedure design/parameters, ratification by appropriate committees, and ensure corresponding appropriate communication and training across footprint.
• provide regional support to senior CIC management (business heads, COOs and PGCs representatives) to ensure that they establish and monitor appropriate processes for compliance with legal and compliance policies, procedures and standards (including meeting legal and regulatory obligations and maintaining high standards of conduct).
4. Regulatory Reform and Horizon Risks
• Support the Product and Segment L&C Leadership Teams and FCC to anticipate horizon risks that may have a significant impact on CIC and develop effective strategies to mitigate such horizon risks including global standards for conduct of business.
5. Reporting
• Support the Regional Head, L&C to provide reports to relevant Committees and Management Groups, and senior management on key L&C risks and issues.
6. Issues Management
• In the event of regulatory or policy breaches, or where risk tolerances have been breached, within CIC in Africa support the Regional Head, L&C to ensure Business and L&C management, and potentially relevant regulators are informed and that actions are taken quickly to remediate and/or activities are ceased.
7. General
• Ensure close coordination with Group Legal litigation teams/GSAM for L&C related input into litigation cases concerning Corporate & Institutional clients.
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