The posting
This role is suitable for individual who has proven hands-on experiences in doing KYC, Customer Due Diligence (CDD) & client onboarding in the Private Banking / Wealth Management space.
The CDD Business Advisory 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 initiate trigger 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 Account Opening reviews, Periodic Reviews and Trigger Reviews for Wealth Management (“WM”) clients, with a focus on assessing client profiles, corroborating and uplifting Source of Wealth (“SoW”), reviewing transaction activity, and ensuring that Customer Due Diligence (“CDD”) requirements are completed in line with regulatory expectations and the Branch’s internal policies and procedures.
The role requires sound professional judgement in evaluating complex client profiles, identifying material risk changes, assessing documentation gaps, and determining whether enhanced review, additional corroboration, risk mitigants, conditions, or escalation is required on a risk-based basis. The job holder is expected to ensure that review conclusions are well-reasoned, clearly documented, and aligned, with regulatory expectations and the Branch’s internal policies and procedures.
Key Responsibilities
- CDD Review Coverage: Conduct CDD reviews for WM clients across account opening, periodic reviews and trigger reviews. This includes reviewing client profile, ownership and control structure, risk rating, purpose of account, expected and actual transaction activity, connected parties, adverse news, documentation validity, SoW, and material changes or risk events. Assess whether CDD requirements are met and determine, on a risk-based basis, whether additional information, documentation, corroboration, risk mitigants, conditions, or escalation to Compliance and Senior Management is required.
- 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 SoW Due Diligence.
- Risk-Based Assessment: Apply a risk-based approach when assessing client profiles and SoW, determining the scope and depth of review requiredbased 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 SoW 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 assess consistency with the client’s stated profile and SoW, 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 account opening, periodic review and trigger review outcomes.
Main Tasks
- Conduct end-to-end CDD Reviews (including uplift of SoW) for WM clients, applying a risk-based approach to determine the scope, depth, and intensity of review
- Assess client profiles, SoW, and transaction activity in a manner proportionate to the client’s risk rating and complexity, to determine whether the overall risk profile remains appropriate.
- Determine whether additional information, corroboration, risk mitigants or escalation is required, based on risk considerations.
- 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
- Liaise regularly with Front Office to discuss pipelines and workload planning.
- Review status and prioritization of CDD review requests
- Support tracking of key account opening, periodic review and trigger review deliverables.
- Assist HoD in addressing or following up on audit queries from internal and external auditors.
- Raise concerns or observations to HoD on a timely basis.
- Assist HoD in closing audit observations / findings within agreed timelines.
- Assist HoD with new and ongoing projects rollouts including UAT and co-ordinate with operations, IT, operations risk, compliance, group units as required
- Assist HoD to update policies and procedures, where required.
- Assist in management of outsourcing activities (i.e., conducting sampling checks, participate in periodic service review meetings etc.).
- Assist HOD with CDD related inputs required for completion of annual Financial Crime Risk Assessment “FCRA” and engage Businesses to review and agree on the responses.
- Interact regularly with key stakeholders, including Compliance, Front Office, Operations and Head Office teams, to build strong partnerships and remove roadblocks
- Engage regularly with team members to support team cohesion and knowledge sharing
- Prepare department meeting minutes to document discussion points and follow-up actions.
- Prepare training / presentation decks and conduct training where applicable.
- Perform other ad hoc tasks as assigned by Head of Business Governance / CBAS Head.
Requirement
- Min 8 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)
- In depth working knowledge of CDD / Compliance / AML procedures and standards in the Private Banking / Wealth Management space.
- Proficient in MAS regulations and guidelines relating to Anti Money Laundering (AML) and Counter Financing of Terrorism (CFT)
- Strong judgement and analytical skills with high attention to detail and accuracy
- Prior experience of adhering to controls and compliance standards
- Strong time management, organizational, relationship building skills
- Strong verbal, written, presentation and communication skills
- Good leadership in providing advisory and guidance to junior team members
- Multi-tasking: Ability to handle multiple tasks on hand and complete them simultaneously
- Ability to understand issues raised by Front Office and resolve the situations
- Positive working attitude and analytical skills
- Good relationship management skills
- Self-motivated and resourceful
- Collaborative and Team player
- Adaptable to fast changing environment
*Note that salary commensurate with relevant experience.
