Major Challenges
HSBC is an extremely diverse business with significant geographical spread and activities that span a universal banking model, including continuing to innovate to keep abreast of changes in financial services markets globally. Such activity is in an increasingly regulated and complex global environment with often little consistency between laws and regulations in different jurisdictions and regulators taking a far more proactive approach in ensuring local compliance with their requirements and imposing increasingly stringent sanctions for breaches. It is the role of the Financial Crime Manager, as a key senior member of the Japan Compliance function to assist HSBC Japan in achieving a balance between the demands of regulators, external bodies and governmental initiatives and the Group’s shareholders and customers in enacting financial crime; being alive to the political, management, regulatory and reputational implications of a particular decision and courses of action at a global level; assisting executive management in the development of controls and systems and influencing the way in which the business is conducted in order to manage these risks, meeting Group risk appetite. The increased focus on individual liability for senior managers, particularly risk heads, makes it increasingly important for the Group to be able to evidence adequate systems and controls. The role is one where regulatory authorities have high expectations and is likely to come under scrutiny as part of any major regulatory investigation.
Role Context
The role holder has senior accountability for implementing business-critical set of policies and operational activities in managing and leading on financial crime across HSBC Japan. This can involve dealing with major issues for which there is no clear cut solution whilst still being able to provide judgement and clear direction. Where items of major consequence are involved, engagement with the relevant top level management and governance bodies will be expected, directly and through collaboration with the Chief Compliance Officer. The nature of the role requires close working contact with other senior executives across the HSBC Japan but particularly the R&C department. Appropriate presence in external stakeholder fora may also be necessary.
