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 required based 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.
Job Requirements
- 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.
(For Salary Range, please refer to our Job Ad posted in MyCareerFuture)
*For Singapore Citizen and Singapore PR, please apply via MyCareerFuture Portal.
At ENBD, we encourage interested candidates to review the key responsibilities and qualifications for each role and apply for positions that match their skills and capabilities.
