AML Surveillance Analyst II (SP7) - Risk Management
Bank Windhoek
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About the role
**Introduction** The AML Surveillance Analyst II is responsible for supporting the effective implementation, monitoring, and enhancement of Bank Windhoek’s Anti-Money Laundering, Counter Financing of Terrorism and Counter Proliferation Financing (AML/CFT/CPF) framework. The role provides specialist AML/CFT/CPF compliance oversight, regulatory reporting, transaction monitoring, risk assessments, and regulatory engagement functions to ensure compliance with applicable AML/CFT/CPF legislation, regulatory requirements, and internal policies. The incumbent will supervise AML Surveillance Analyst I personnel, provide subject matter expertise to business units, support the identification and mitigation of money laundering, terrorist financing and proliferation financing risks, and contribute to the continuous improvement of the Bank’s AML/CFT/CPF programme. **Job description** KEY PERFORMANCE AREAS (KPAs)1. AML Compliance Oversight and Advisory Manage and develop direct reports (AML Surveillance Analyst I staff), including workload allocation, performance management, coaching, training and succession cover.Provide independent AML/CFT/CPF advice and challenge to business units, keeping a record of material advice given, with the business retaining ownership of its risks.Monitor AML/CFT/CPF compliance across the Bank through a risk-based monitoring plan, and escalate unresolved non-compliance to the Manager: AML Compliance and senior management, tracking remediation to closure.Prepare and approve management information on AML/CFT/CPF performance and risk (such as alert ageing, reporting timeliness, training completion, breaches and findings) for governance and management committees.Review and maintain AML/CFT/CPF policies, standards and procedures at set intervals and on regulatory change, with documented approval and version control.Contribute to institutional and business-unit ML/TF/PF risk assessments.Track audit, regulator and FIC findings to remediation and report progress.Administer exceptions and waivers in line with approved governance. 2. Go-AML related Data Quality & Errors Remediation – Daily CTR/EFT (local & Cross-border) ReportsOversee the timely identification, investigation and correction of reportable transactions with data quality errors in XML files, including validation against the current goAML schema before upload.Check for rejected or partially accepted XML files in goAML at set intervals, and refer them to the [BW ITO Department / Enterprise Service Platform] for remediation without delay.Engage the relevant business units to correct source data errors, and identify root causes of recurring errors.Track remediation to completion, ensuring accurate resubmission to the FIC within five working days of [the transaction date / the date the error was identified].Maintain a log of errors, rejections, corrections and resubmissions, and report error rates and ageing to management.Escalate promptly where the deadline is at risk or missed.3 3. SharePoint Processing (Co-pilot) Maintain and manage Go-AML PDF reports by accurately saving them to the designated shared drive to support timely and reliable updates of the Compliance Dashboard.Upload Go-AML PDF reports to the Uncounted Reports module and proactively monitor automated processing to ensure completeness, accuracy, and timely resolution of exceptions.Identify, escalate, and track SharePoint‐related processing issues by logging ME calls with the IT Department and following up to ensure effective resolution within agreed timelines.4 4. Dual control of alerts in SIRON AMLPerform dual control (second-level review and approval) of alerts investigated by AML Surveillance Analyst I staff in the SIRON AML system, in line with approved procedures and turnaround times.Confirm that each alert disposition (closure, escalation or referral) is supported by an adequate investigation, a clear rationale and sufficient evidence before approving it in the system.Return inadequately investigated alerts to the analyst with documented feedback, and track them to resolution.Apply mandatory dual control to high-risk alerts, potential sanctions matches, PIP-related alerts and alerts recommended for escalation or regulatory reporting.Maintain segregation of duties by never reviewing or approving an alert that you investigated yourself, and by working within the access rights assigned in SIRON.Escalate overdue, inadequately investigated or high-risk alerts to the Manager: AML Compliance without delay.Ensure the SIRON audit trail is complete and accurate, including the reviewer’s decision, date and comments, to support regulatory inspection.Monitor alert queues and ageing, and report review volumes, turnaround, rejection rates and recurring quality issues to management.Use review findings to coach analysts and to recommend improvements to scenarios, thresholds and procedures.. 5. AML/CFT Investigations Conduct or oversee investigations into suspected money laundering, terrorist and proliferation financing and sanctions breaches, assigning cases and reviewing complex or high-risk matters directly.Perform risk-based quality assurance of client-screening, transaction-screening and transaction-monitoring alerts investigated by AML Analysts, in line with approved procedures and turnaround times, with mandatory review of high-risk, sanctions and escalated cases.Ensure investigations correctly identify and assess prominent influential persons (PIPs), high-risk clients and potential sanctions matches, with clear rationale and evidence.Validate the adequacy, accuracy and completeness of each reviewed investigation, including the disposition rationale and any mitigating actions.Ensure confirmed sanctions matches are escalated without delay and that freezing, blocking and reporting obligations are met in line with applicable law.Escalate overdue, inadequately investigated or high-risk alerts to the Manager: AML Compliance or senior management without delay, with recommendations for further investigation, enhanced due diligence, account restrictions or regulatory reporting.Maintain complete case records, provide feedback to analysts, and use trends to improve scenarios, thresholds and training.Report on alert volumes, ageing, quality and backlogs to senior management.Maintain confidentiality and prevent tipping off in all investigations. 6. Regulatory Reporting OversightOversee the preparation, review and filing of Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs), Additional Information Files (AIFs) and all other AML/CFT reports required by the Financial Intelligence Act and FIC directives, ensuring they are accurate, complete and filed within the prescribed timeframes.Review and approve reports before filing, perform quality assurance on a sample basis, and track filing deadlines and outstanding items in a reporting log.Follow up reports rejected or partially accepted by goAML and ensure corrections are resubmitted on time.Review Single Discretionary Allowance (SDA) transactions above the approved, risk-based threshold, to confirm they are consistent with the client’s profile and that source of funds, purpose and supporting documents are adequate and the risks identified are resolved.Escalate unexplained or inconsistent transactions to the Manager: AML Compliance, consider reporting obligations, and maintain confidentiality to prevent tipping off.Report on filing volumes, timeliness and quality to senior management, and escalate late or missed filings with the root cause.Maintain records of the rationale for reporting decisions, and use FIC feedback to improve analysts’ report quality. 7. AML/CFT/CPF Training and Awareness Conduct a training needs analysis and design risk-based AML/CFT/CPF training programmes for all staff, tailored by role, including induction, annual refreshers and specialised training for higher-risk areas. Deliver training in classroom and virtual formats, and brief senior management and the board. Own and approve compliance awareness materials and guidance notes, and keep them current with legislation, typologies and regulator feedback. Track attendance and completion, follow up non-completion, assess effectiveness through testing and feedback, and report results to management. Maintain training records for regulatory inspection. Promote a strong compliance culture by encouraging staff to raise concerns and escalate suspicious activity, working with senior management and the business. Develop the AML capability of direct reports. 8. Research and Continuous Improvement Monitor local and international AML/CFT/CPF developments, regulatory trends and emerging financial crime risks, assess their impact on the Bank and report significant matters to senior management.Benchmark the Bank’s controls against FATF standards, Wolfsberg guidance, FIC directives and industry practice, and prepare gap analyses with action plans.Lead the implementation of process and control improvements that strengthen regulatory compliance and operational effectiveness, tracking results against agreed measures.Use lessons from regulatory feedback, inspections, audit findings and investigations to enhance monitoring, screening, KYC processes and training.Review AML/CFT/CPF policies and procedures at set intervals and when regulation or risk changes.Evaluate technology and automation solutions to improve detection and efficiency, and recommend them to management.Contribute to strategic initiatives that strengthen the Bank’s financial crime risk management framework.9. Regulatory EngagementAct as the institution’s point of contact for the Financial Intelligence Centre (FIC) on AML/CFT/CPF matters, escalating significant issues to senior management.Notify the FIC of identified data quality issues in transaction reports, in accordance with regulatory requirements and within the prescribed timeframes.Identify, log and report goAML portal issues to the FIC and management, and track them to resolution.Respond accurately and within the required timeframes to queries from the FIC, the Bank of Namibia and law enforcement agencies, after verifying the authority and scope of each request and obtaining legal review where appropriate.Execute and coordinate intervention orders issued under the Financial Intelligence Act, ensuring compliance with the order, recording the action taken and maintaining confidentiality.Coordinate regulatory inspections and track findings through to remediation.Maintain a log of all regulatory and law enforcement correspondence.Represent the institution at FIC and industry forums and meetings.Supervise team members who prepare regulatory submissions and responses.10. GeneralContribute to AML/CFT/CPF compliance projects and initiatives as assigned by management.Monitor developments in local and international AML/CFT/CPF legislation, regulatory requirements and guidance (including the Financial Intelligence Act, FIC directives, PACOTPAA and FATF standards), assess their impact on the institution and recommend changes to policies, procedures and controls.Keep abreast of emerging ML/TF/PF typologies and incorporate relevant trends into risk assessments, monitoring scenarios and training.Apply compliance best practice in the performance of all duties.Maintain complete and accurate records of all data collected, processed and analysed, retained for the period required by law and retrievable for regulatory inspection.Ensure the secure handling and confidentiality of sensitive regulatory data, including STR information, and prevent tipping off.Perform other duties as reasonably assigned.Core CompetenciesIntegrity and ethical judgement: acts honestly, maintains confidentiality, and escalates concerns regardless of seniority or commercial pressure.Analytical and critical thinking: analyses complex information, identifies patterns and risks, and reaches sound, well-reasoned conclusions.Attention to detail: produces accurate regulatory reports, records and documentation.Independence and initiative: works with minimal supervision, takes ownership of issues and drives them to closure.Planning and organisation: manages competing priorities and meets regulatory deadlines.Communication and influence: writes clearly, presents to senior management, and engages the business, regulators and law enforcement effectively.Leadership and people management: guides, develops and holds direct reports accountable, and builds a strong compliance culture.Composure and resilience: stays calm under pressure, handles disagreement constructively and adapts to change. **Minimum requirements** QualificationsBachelor’s degree in commerce, law, finance, accounting, economics or a related field.Diploma in Anti Money Laundering or Compliance will be distinct advantage.Certification in a professional association such as the Association of Certified Anti- Money Laundering Specialists (ACAMS) would be a distinct advantage. 2. ExperienceMinimum of [5] years’ experience in AML/CFT, financial crime or compliance within a financial services environment.Minimum of [2 to 3] years’ experience supervising staff or managing a function.Working knowledge of the Namibian AML/CFT legislation.Experience engaging with regulators and law enforcement agencies, including responding to information requests and inspections.Experience managing AML/CFT/CPF controls and the systems that support them, such as transaction monitoring, screening and KYC tools.Strong analytical skills, with the ability to organise and analyse large, complex data sets and report clearly to senior management.Proficiency in Microsoft Excel, with [SQL, Power BI or equivalent] preferred.Strong interpersonal and organisational skills.
Requirements
- Bachelor’s degree in commerce, law, finance, accounting, economics or a related field.
- Diploma in Anti Money Laundering or Compliance will be distinct advantage.
- Certification in a professional association such as the Association of Certified Anti- Money Laundering Specialists (ACAMS) would be a distinct advantage.
- Minimum of [5] years’ experience in AML/CFT, financial crime or compliance within a financial services environment.
- Minimum of [2 to 3] years’ experience supervising staff or managing a function.
- Working knowledge of the Namibian AML/CFT legislation.
- Experience engaging with regulators and law enforcement agencies, including responding to information requests and inspections.
- Experience managing AML/CFT/CPF controls and the systems that support them, such as transaction monitoring, screening and KYC tools.
- Strong analytical skills, with the ability to organise and analyse large, complex data sets and report clearly to senior management.
- Proficiency in Microsoft Excel, with [SQL, Power BI or equivalent] preferred.
- Strong interpersonal and organisational skills.
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