• MANDATE:

The Manager, Anti-Money Laundering Compliance under the direction of the BMO China National Compliance officer is responsible for assessing and monitoring the activities of BMO China’s Anti-Money Laundering and Terrorist Financing (AML/ATF) compliance program, investigating suspected Money Laundering and Terrorist Financing transactions and for reporting of these transactions to the People’s Bank of China (PBOC), the China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC), and, if appropriate, to Public Security organs, and to senior Management and as well as the BMOFG Chief Anti-Money Laundering Officer (CAMLO) as required. The primary objective of the position is to ensure that BMO’s AML/ATF processes (e.g. customer identification, account documentation, record keeping and prescribed transaction reporting) are in compliance with Anti-Money Laundering and Terrorist Financing (AML/ATF) legislation and regulations in People’s Republic of China. Specific accountabilities are outlined below.

• KEY ACCOUNTABILITIES

The Manager, Anti-Money Laundering Compliance Office is accountable for:

1. Identify, assess, document and report on AML/ATF risks by the business in order to ensure that the business’ AML/ATF policies and procedures are defined and implemented in compliance with policy and regulatory requirements and expectations;
2. Develop, implement and maintain policies and procedures as required by PBOC and CAMLMAC’s legislation and regulations and ensure, to the extent possible, that BMO China’s AML/ATF policies and procedures align with Enterprise wide AML policy requirements and head office procedures developed by specific lines of business.
3. Establish and apply review/monitoring policies and procedures in China, regularly testing their effectiveness and reviewing findings with the Senior Management of Marketing, Operations and the National Compliance Officer;
4. Monitor BMO China Branches’ mandatory transaction reporting process to ensure that regulatory requirements are met and in compliance with Anti-Money Laundering and Terrorist Financing (AML/ATF) legislation and regulations in People’s Republic of China;
5. Ensure reporting Exemptions, Record Keeping, Client Identification and related “know your client” requirements are implemented, if applicable;
6. Support the business through direct participation in the development and implementation of new processes, systems enhancements etc. to facilitate compliance with AML/ATF requirements;
7. Develop training aids/materials and conduct on-going employee compliance/training sessions internally in China to educate staff on compliance issues related to the Legislation, policies, procedures and suspicious transaction activities, including the completion of reports, as applicable;
8. Assess the appropriateness of BMO China’s Money Laundering detection processes with consideration of systems support and monitoring capabilities;
9. Identify controls and measures that provide early warning of potential failure to meet AML/ATF risk management objectives;
10. As required, develop and maintain internal management reports, external management reports and periodic reports and/or presentations to Senior Executive and/or regulators;
11. Liaise with Public Security Organs specifically mandated by PBOC for timely reporting of suspicious transactions;
12. Maintain effective and smooth communication channel with regulators in charge.
13. Report any significant AML/ATF events on a timely basis and provide periodic reports on the status and performance of BMO China’s AML/ATF compliance program to senior management and the National Compliance Officer, the BMO Financial Group CAMLO or as otherwise directed by the National Compliance Officer.

• AUTHORITIES:

To deliver on these accountabilities, the Manager, Anti-Money Laundering Compliance Office must have the following authorities:

Governance – has the authority to develop and recommend new frameworks and processes including risk policy and principles to govern AML/ATF risk

Advisory - has the authority to provide advice and counsel to his/her colleagues on proposed strategies.

Recommending - has authority to recommend policies, procedures and standards for compliance within BMO China Branches.

Coordinating - has the authority to coordinate work and/or call people together to discuss/resolve issues. Can persuade people to change course and/or act in concert with each other.

Monitoring - has the authority to collect or be provided with the required information from others when reviewing and reporting on Anti-Money Laundering and Terrorist Financing issues, determining effectiveness of current programs and reviewing items.

Auditing - has the authority to examine the work of others to ensure compliance with all AML regulatory requirements.

Investigative – has the authority to examine transactions, agreements, documentation and decide whether to approve them or not. Has the authority to stop activities/documents outside the standards.

Approval - has the authority to approve/stop activities/documents/transactions outside standards in BMO China Branches.

• KNOWLEDGE AND SKILLS:

Knowledge:

1. Completed University degree in Finance, Business Administration or similar and 3-5 years of related experience. Related experience may include: branch banking and systems, bank operations, audit, compliance or law office;
2. A thorough knowledge of all Bank Operations;
3. Excellent verbal and written communication skills both in Chinese and English;
4. Excellent networking skills.
5. Regulatory Background would be considered an asset.

Skills:

1. Strong investigative and analytical ability
2. Exceptional organizational skills.
3. Demonstrated above average judgment, decisiveness,
4. Utmost discretion and diplomacy
5. Aggressive/able to pursue and resolve obstacles encountered
6. Ability to perform under pressure
7. Sound relationship management ability; able to deal with peers and others in BMO China Branches and with external regulators and Public Security Organs.