Reporting to the Vice-President and Chief AML Officer, the Director, High Risk/Enhance Due Diligence (HR/EDD) is responsible for management oversight of the activities of a group of analysts within the AML Group devoted to the identification, assessment and monitoring of all high risk clients, as defined by the CIBC Client Risk Assessment Standard.
The Director is accountable and responsible for identifying all high risk client relationships in Canada and globally and conducting thorough analysis of those relationships in order to adequately assess and address the risks posed to CIBC by the clients, while complying with regulatory requirements.
The Director is also responsible for ensuring that mandatory client information is gathered, verified and updated in respect of all high risk clients, enterprise-wide. The consequences associated with non-compliance in this regard are potentially severe and far-reaching, including potential criminal penalties against CIBC’s senior executives and members of the Board of Directors.
The Director is accountable for providing leadership, direction and coaching to the HR/EDD team of analysts in managing the process of information collection, consolidation, analysis and reporting. This information is used to assess the risks posed to CIBC by maintaining high risk client relationships.
The Director is accountable for ensuring that policies, practices and procedures are developed to protect CIBC from undue risk, civil and criminal liability associated with money laundering and terrorist financing conducted by high risk clients.
The Director is also accountable for delivering effective data analytics relating to high risk clients. Further, the Director will identify internal procedural and control weaknesses in respect of high risk clients and independently develop and implement solutions to address such weaknesses.
What You’ll be Doing
Performs management oversight and directs the identification and investigative activities of the High Risk/EDD AML Analysts by establishing priorities, supervising, conducting quality assurance reviews, and ensuring the general quality of the work product of the High Risk/EDD team.
Manages and directs High Risk/EDD Analysts efforts to obtain and document mandatory enhanced client information by documenting the requirements pertaining to the required information and engages directly with executives and senior management in the LoBs where the required information is not forthcoming.
Provides ongoing management oversight with respect to all reporting of statistics/information pertaining to the High Risk/EDD team to executives and senior management within the line of business and other lines of business or governance groups within CIBC.
Researches regulatory changes and industry trends and makes recommendations to senior AML management to enhance the AML Program as it relates to the identification, assessment, monitoring and reporting of high risk clients.
Develops and delivers effective data analytics relating to high risk client cohorts to senior AML management and executives across CIBC’s LoBs, globally.
Identifies internal procedural and control weaknesses in respect of high risk clients and independently develops and implements solutions to address such weaknesses.
Maintains AML Compliance’s methodology, practices and procedures relating to the identification, assessment, monitoring and reporting of high risk clients and high risk client activity.
Provide oversight in the implementation by the LoB’s of AML/ATF processes and procedures related to high risk clients to ensure consistency with the CIBC AML.
Assists the Director, AML Projects with the development of the methodology for assessing AML/ATF risks associated with high risk clients.
Contributes to the development of non-routine and specialized content for supplemental training for lines of business exposed to more complex AML/ATF risks based on the fact that they deal largely with high risk clients (such as Correspondent Banking and Private Wealth Management).
Contributes to the preparation of responses to regulatory and Internal Audit examinations of AML/ATF in relation to high risk clients, and assist with the development and implementation of appropriate corrective action plans by LoBs where deficiencies relate to high risk client practices.
Researches and reports upon industry best practices relating to high risk clients and enhanced due diligence and actively monitors regulatory changes in that regard.
Pro-actively monitors business changes relating to high risk clients requiring updates to AML procedures and standards and implements all required changes to AML Compliance controlled-documents.
Develops processes and templates to deliver data analytics capabilities and practices.
Prepares and delivers comprehensive presentations regarding the high risk client and enhanced due diligence components of CIBC’s AML Program to senior management and executives, enterprise-wide.
Contributes high risk client/EDD information to the content of reports regarding the AML Program for ultimate delivery to the Governance and Control Committee, the Senior Executive Team and the Board of Directors.
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