The main purposes of the job are: (i) to conduct risk-based, independent and onsite Compliance and Financial Crime reviews (hereafter `Compliance reviews´) designed to review the effective implementation in AXA entities of the Compliance, Financial Crime and Data privacy Group, Regional and local requirements; and (ii) carry out compliance oversight, monitoring and support to the Asia entities belonging to the INM (i.e. Malaysia, India and Singapore).
(i) Compliance and Financial Crime Reviews
As a second line of defense, Compliance should perform controls on a regular basis to ensure the appropriateness and adequacy of Compliance resources, procedures and systems and the effectiveness of the internal control environment linked to Compliance, Financial Crime and Data Privacy.
With this objective, the Compliance & Financial Crime Testing Senior manager will conduct annually a series of onsite Compliance reviews in AXA entities. It is noted that those review will be conducted in a team made at least of two Compliance and Financial Crime Testing Senior Managers. The reviews will be structured around the following main phases:
1. Preparatory phase:
design and enrich Compliance and Financial Crime control programs related to all the dimensions of the reviews from various sources, both internal (standards, policies, real cases, etc. ) and external (regulatory programs, compliance literature, industry best practices, etc.)
Notify officially the entities´ executive management and some key stakeholders about the objective, content and timing of the Compliance review.
Coordination with the entities in anticipation of the onsite visit: materials to be shared in advanced, preliminary questions and calls, agenda and logistical preparation
2. On site review:
The onsite reviews will constitute the core part of the entity’s compliance reviews. To give an indication of timing, it is expected the onsite reviews to last at least one week, with the view of being extended when it is felt necessary, such as reviews occurring in large entities or where complexity of the topics is higher.
During the onsite review, the Compliance & Financial Crime Testing Senior manager will lead a number of interviews with various stakeholders in order to get a deeper understanding of local processes and of the organization in order to extract and analyse all the necessary and relevant information for the accomplishment of the assignment
Compliance Control program: The Compliance & Financial Crime Testing Senior manager will go through the various dimensions of pre-defined Compliance control programs to check whether controls expectations are met, and if not document any breach. Controls intend to be risk-based, i.e. the Compliance & Financial Crime Testing Senior Manager will focus first on the effectiveness of controls linked to the main Compliance risks, as reported annually by the Compliance function
Sample analysis. The Compliance & Financial Crime Testing Senior manager will select for most controls a sample of data related to customers, transactions, products, services, employees, third parties, and any other relevant areas to gauge and report on the effectiveness of embedded compliance controls and adherence to Group Compliance Standards and entities´ Compliance procedures. For instance, control will consist in checking few months after the issuance of a Group Compliance Standard/Policy that it has been effectively locally implemented (e.g. new sanctions, new clause to be integrated, new ban on some business, new rules on sales suitability, etc.).
The ability of the Compliance & Financial Crime Testing Senior Manager to extract, analyze and draw conclusions from the right sample of data (from management systems, accounting, customers´database, etc.) will be a key success factor of the Compliance review.
Working programs: All the findings of the internal control reviews will be documented and formalized into working programs that will be filled out in the course of the onsite reviews
Findings will be discussed with the entities ‘stakeholders to ensure their accuracy and their appropriateness from local management
After the onsite review, additional questions and exchanges will be organized with the entity to finalize the review
A synthetic report will be designed gathering all the findings identified and locally validated.
The report will be then finalized and shared with the relevant Group, Regional and local stakeholders.
An action plan is then expected to be produced by the entity with detailed tasks and timing to be enforced within a prescribed timing to face the issues and findings raised during the review.
4. Library of controls
The Compliance & Financial Crime Testing Senior manager will enrich and maintain the library of Compliance and Financial Crime control at any time, before, after or in the course of a Compliance review
The Compliance & Financial Crime Testing Senior manager will liaise with the other regional Compliance managers to monitor entities´ implementation of Compliance controls and action plans
5. Duration of a review
As an indication, a review should be covered within1-1,5 months, depending of the size of the entity and the scope of topics covered
It is expected that adhoc reviews could be performed at any time upon request from the management of the Group/ Asia Markets.
The Compliance Monitoring & Testing Senior Manager could support as well any M&A due diligence by demonstrating active monitoring/mitigation of compliance issues
It is reminded that a key component of the position lies in the ability to challenge the substance reported by the entities and to drive the quality of the deliverables. The position requires some capacity to understand Compliance, legal issues but also to a certain extent accounting (to extract adequate data) to be in a position to locally challenge the substance. It also requires a certain level of assertiveness, autonomy and seniority to be able to defend he/her opinion, based on his/her actual findings, to convince local management and to face and manage any potential conflictual situations that could emerge from the review.
Finally, the job position contributes to support the maturity of the Compliance function across the Group and to ensure an efficent relationship with the Group and external parties, such as auditors and regulatory authorities.
(ii) Anti-Bribery and Cross-Border Business
· Assist in the design, definition and documentation of effective compliance frameworks and supporting practices, policies and procedures to support organisational obligations with respect to Cross Border Transactions (with a particular focus on tax evasion) Anti Bribery, FATCA and CRS.
· Facilitate and oversee the effective implementation of anti-bribery framework into all entities operating under the Asia Markets infrastructure
· Assist in reviewing any Cross-border business application from Asia Markets entities and liaising with Group Compliance to seek approval Cross-border Businses
· Taking primary responsibility working with the entities to develop training and communications materials relevant to the Group anti-bribery topics
· Oversee the development and implementation of an ongoing compliance monitoring framework aimed at ensuring operational effectiveness of elements (identified through a robust risk assessment) of the financial crime compliance framework. This compliance monitoring framework is to be coordinated and driven by the Asia Markets Corporate Centre
· Prepare accurate and comprehensive responses to all AXA Group reporting and ad hoc requests received by the Asia Markets for review by General Counsel and Head of Compliance before release
· Prepare accurate and comprehensive reports, as required, by regional and/or local entity management committees and/or executive members. General Counsel and Head of Compliance oversight will be applied as deemed appropriate.
· Assist the General Counsel and Head of Compliance with the preparation of annual compliance operating plans highlighting matters of anti-bribery or cross-border topics that require attention
-Around 5-10 years experience of working in Compliance, Financial Crime, Internal or External Audit or in Sales, Distribution or Underwriting in insurance
-Availability for travelling
-Legal background is a plus
-Fully proficient in English
-Have a good understanding of, and build a good relationship with, the other control functions (Risk and Audit) and with the Group