(UK) London, Sanctions Advisory Manager - Barclays
Barclays is an international financial services provider engaged in personal banking, credit cards, corporate and investment banking and wealth management with an extensive presence in Europe, the Americas, Africa and Asia. Barclays’ purpose is to help people achieve their ambitions – in the right way.
With over 300 years of history and expertise in banking, Barclays operates in over 50 countries and employs approximately 140,000 people. Barclays moves, lends, invests and protects money for customers and clients worldwide.
For further information about Barclays, please visit our website www.barclays.com.
About Financial Crime
The Financial Crime team helps ensure that Barclays complies with anti bribery and corruption, anti money laundering and sanctions legislation.
Sanctions are restrictions on activity with targeted countries, governments, entities, individuals and industries that are imposed by bodies such as the United Nations (UN), the European Union (EU), individual countries, including the United Kingdom and the United States, or groups of countries. Sanctions can be applied unilaterally or collectively and different rules may apply to each sanctions regime.
The Sanctions team, within Barclays Financial Crime, is a group of policy and subject matter experts who are dedicated to:
Partnering with the business and delivering expert second line guidance to ensure mutual confidence in the management of their sanctions risk.
The management of a compliance culture which will ensure that Barclays discharges its regulatory responsibilities in respect of the fight against Financial Crime and the funding of terrorism.
Overall purpose of role
The role holder reports into the business-aligned Head of Sanctions within the wider Group structure of Sanctions and provides subject matter expertise to all key stakeholders with regards to on-going compliance with the Group Sanctions Policy.
The role holder will primarily support the overall management of sanctions risk for the aligned business by providing guidance and input to critical or technically complex business initiatives, building strong partnerships with the business partners, supporting first line of defence operational areas in ensuring compliance with sanctions policy, monitoring (and managing where appropriate) controls associated with sanctions and promoting a culture of risk control across the business and Financial Crime.
The primary purpose of this role is to:
- Understand and manage sanctions Risk.
- Provide up-to-date interpretation of sanctions legislation and regulation ensuring Barclays meets its legal and regulatory responsibilities.
- Be a point of escalation for the business and shared service teams for sanctions related issues or tasks.
- Provide expert advice and guidance to relevant stakeholders on the application of the Sanctions Policy.
- Apply in-depth knowledge of regulations and internal policy and, where necessary, employ subject matter expertise in making risk-based decisions when reviewing escalations from the business and shared services to confirm whether potential sanctions lists matches are actual matches.
- Provide an advisory service to first line of defence staff within the business, employing subject matter expertise to resolve queries in respect of Financial Sanctions and or internal Sanctions Policy.
- Understand the rules that govern the automated sanctions screening solutions which identify any potential matches, understanding the logic rules that create such matches.
- Manage the preparation of exceptions, dispensations and waivers against Sanctions Policy, by way of collaboration with the business, after case-by-case analysis of the circumstances.
- Provide recommendations to Sanctions Advisory Team on how financial crime controls can be developed.
- Maintain oversight of and manage correspondence with operational dependencies with a view to ensuring that escalations are being made correctly and minimum standards are being met: establishing an open dialogue with a view to ensuring best working practices for the mutual benefit of both areas.
The role holder will primarily support the overall management of sanctions risk for the aligned business by providing guidance and input to the business, ensuring internal standards and risk appetite are met. The role holder will need to effectively manage a number of stakeholders at varying levels to achieve this.
Key responsibilities will include:
Relationship / behaviour:
- Display role model behaviors as per Barclays’ values.
- Act and be seen as an ambassador in sanctions risk prevention.
- Build trusted relationships with key business stakeholders.
- Understand the objectives of the Sanctions team and the control frameworks and embed a culture of compliance with sanctions.
- Play a critical role in delivery of Barclays’ sanctions strategy.
- Collaborate with the business in the implementation of Group and local policy standards and controls.
- Manage the BAU activity and evolution of policy events, ensuring that staff possess an appropriate skill level (technical and procedural) to carry out their duties in a complex and continually evolving external environment.
- Oversee the completion of breach reports, exceptions to policy and US/UK regulator voluntary disclosures by the business where necessary and in a timely manner.
- Develop, where appropriate, standards and procedures that comply with Group policy and local businesses’ risk appetite.
- Manage and provide the business with guidance in the completion of complex sanctions investigations.
- Ensure that sanctions matters are correctly managed and follow appropriate escalation routes, while involving the relevant stakeholders early and fully.
- Oversee and assist where appropriate with responses to requests from internal audit and conformance teams.
- Act as trusted advisor to the aligned business in sanctions matters.
- Maintain a path of ongoing professional development with respect to sanctions legislation and develop understanding of the aligned business to remain informed on both sanctions matters and also Barclays’ matters.
- Provide SME expertise around the management of high risk accounts and payments to the business.
- Be the ‘go-to’ person for sanctions advice and provide in depth analysis from a sanctions (and wider financial crime) perspective.
- Provide day to day advice on Sanctions Policy matters and support the business units in providing advice relating to relationships, transactions and regulatory issues.
- Provide ad-hoc advice and direction to the business on sanctions operations and procedures, so as to meet both local and international legislative and regulatory obligations.
- Assist the business in operational features / advice and guidance on internal and regulatory requirements with respect to sanctions.
Key stakeholders for this role include, but are not necessarily limited to, Heads of Sanctions for the business-aligned teams, Head of Sanctions Advisory Team, Global Head of Sanctions, etc.
The role will require a candidate with confidence to make business critical decisions, with an approachable, resilient, and persuasive manner, and strong negotiation and influencing skills.
The ability to work as part of a team as well as individually is critical to the role, as is the flexibility to tailor their approach to enable positive interaction at all levels of the organization.
Decision-making and Problem Solving
Analytical skills are a pre-requisite for this role, as the candidate will be required to evaluate complex escalations and balance a variety of factors in order to make risk-based decisions consistent with both Barclays Group Sanctions Policy and Barclays Lens.
Risk and Control Objective
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
The right candidate will be able to demonstrate:
- Excellent understanding of OFAC, HMT, EU, and UN sanctions laws, regulations, regulatory expectations and industry best practice.
- Sound judgement and the ability and confidence to make business critical decisions.
- Excellent attention to detail.
- An approachable, straightforward, resilient, persuasive manner, with strong negotiation and influencing skills.
- Ability to work as part of a team as well as individually.
- Self-confidence to articulate opinions in the face of contrary views, where necessary.
- Strong organisational, planning, prioritisation and problem-solving skills, with the ability to multi-task and demonstrate flexible thinking.
- Ability to interact at all levels of the organization, including distilling complex issues to clear and concise briefings for senior management.
- Comprehension of materiality of issues and their potential reputational and regulatory impact, with a clear understanding of when to escalate and to what level.
- Excellent English written and verbal communication skills.
- The ability to develop strong working relationships within key client groups.
- A focus on delivery while working to tight deadlines.
- Competency in accessing a range of data across both internal and external information repositories.
- A strong working knowledge of operational areas which interface with the role.
The right candidate will preferably have:
- A background in sanctions or financial crime.
- An interest in politics and its effect on global regulatory environment.
- A solid understanding of the Barclays Group/Business Units and its major customer/payments processing systems.