The posting
The CDD BusinessAdvisory and Support (CBAS) unit operates as the 1.5 line of defense and functions as a bridge between Branch’s Business segments (1st line of defense) and Control / Support (2nd line of defense) units to support the Corporate& Institutional Banking (C&IB) and Wealth Management (WM) businesses on Client Due Diligence (CDD) related matters including:-
- Documents preparation required for client onboarding and periodic reviews
- Liaising with key stakeholders like Business, Compliance and Ops units to address any gaps in the CDD reviews
- Monitoring of client accounts (including onboarding conditions, adverse news, documentation validity) and initiatetrigger reviews
- Conduct AML/CFT related in-house surveillance reviews along with business and compliance
- Prepare MIS (e.g. monthly CDD statistics report) and respond to AML/ CFT regulatory surveys
- Initiation and implementation of process improvement and digital transformation projects to streamline and automate the name screening and review process
The primary focus of this role is to conduct Periodic Reviews for Wealth Management clients, with the focus on assessment, corroboration and uplifting the Source of Wealth “SoW”. The role requires the exercise of sound professional judgement in evaluating complex client profiles, identifying material risk changes, and determining whether enhanced review or additional corroboration is required on a risk-based approach. The job holder is expected to ensure conclusions are well-reasoned, clearly documented, and aligned with regulatory expectations and the Branch’s internal policies and procedures. Job holder may be required to provide support for onboarding reviews where necessary.
Key Responsibilities
SoW Remediation: Enhancement of source of wealth (“SoW”) corroboration and documentation for Periodic Reviews in line with MAS AML/CFT Notices and ACIP paper - Best Practices on Source of Wealth Due Diligence.
Risk-Based Assessment: Apply a risk-based approach when assessing client profiles and Source of Wealth, determining the scope and depth of review required based on factors such as client risk rating, complexity, transaction activity, and observed changes since the last review.
Professional Judgement on Documentation Gaps: Exercise sound professional judgement where standard or historical documentation is unavailable, assessing whether alternative forms of corroboration (e.g., reputable news archives, statutory filings, or professional references) are reasonable and sufficient, and clearly documenting the rationale for conclusions reached.
Use of Generative AI for SoW Narratives: Leverage the use of generative AI tools to support the drafting of Source of Wealth narratives by consolidating information from sources such as public records, news, and transaction history. Apply professional judgement to review, validate, and refine the outputs to ensure accuracy, coherence, and consistency with the client’s overall profile
Transaction Analysis: Review account transactions to access consistency with the client’s stated profile and Source of Wealth, identify unusual or unexpected patterns, and assess whether further review, clarification, or escalation is required.
Stakeholder Advisory and Risk Mitigation: Work closely with Front Office to provide guidance on addressing identified CDD gaps in a manner proportionate to the customer’s risk profile. Where gaps remain, assess and propose appropriate risk mitigants in line with a risk-based approach, ensuring that decisions are supported by clear and documented rationale. Present and articulate the risk assessment, proposed mitigants, and basis for conclusions to Compliance and Senior Management for review and endorsement, in line with governance and regulatory expectations.
Document Validity and Ongoing Monitoring: Ensure client documentation remains valid and fit for purpose, and that updates are initiated promptly to reflect material changes in client circumstances.
Reporting and Governance: Provide input into CDD dashboards, management reports, and governance updates to support Senior Management oversight of Periodic Review outcomes.
Main Tasks
- Conduct end-to-end Periodic Reviews (including uplift of SoW) for Wealth Management clients, applying arisk-based approach to determine the scope, depth, and intensity of review
- Assess client profiles, Source of Wealth, and transaction activity in a manner proportionate to the client’s risk rating and complexity, to determine whether the overall risk profile remains appropriate
- Identify material changes since the last review and assess whether enhanced review, additional corroboration, or escalation is required, based on risk considerations.
- Support onboarding reviews where required.
- Exercise sound professional judgement when assessing complex client profiles or documentation gaps
- Evaluate the sufficiency of alternative corroboration where standard documents are unavailable
- Clearly document conclusions, assumptions, and risk-based rationale in line with regulatory and internal policies and procedures
- Assess the plausibility of Source of Wealth using a risk-based approach, taking into account the client’s risk rating, complexity, and known activities, and evaluating against transaction history
- Review transaction patterns in a manner proportionate to risk to identify inconsistencies or unusual activity
- Determine, based on a risk assessment, whether further clarification, enhanced review, additional corroboration, or escalation is required
- Work closely with Front Office to address identified CDD gaps in a manner proportionate to risk
- Propose appropriate risk mitigants where gaps remain, supported by documented rationale
- Present and defend risk assessments, proposed mitigants, and conclusions to Compliance and Senior Management
Requirement:-
- At least 5 years of banking industry experience in Private Banking or Wealth Management KYC / CDD or client onboarding (Audit, Risk, AML may also be areas of experience).
- Basic knowledge of CDD / Compliance / AML procedures and standards in the Private Banking / Wealth Management space.
- Good understanding of MAS regulations and guidelines relating to Anti Money Laundering (AML) and Counter Financing of Terrorism (CFT), ACIP Paper on Best Practices on Source of Wealth Due Diligence
- Meticulous and detail oriented
- Problem identification and solving skills
- Good time management skills and adherence to deadlines
- Good verbal and written communication skills
- Demonstrate ownership of assigned tasks
- Motivated and confident
- Self-starter and independent
- Collaborative and Team player
- Adaptable to fast changing environment
*Note that salary commensurate with relevant experience.
