Head - Fraud Control Unit

Role Objective:

The Head of FCU will be responsible for defining, developing, and executing the overarching fraud risk management strategy. This leadership role ensures that the organization is protected against internal, external, and digital fraud across the entire lifecycle of its lending products. The ideal candidate will build robust fraud detection frameworks, oversee complex investigations, manage third-party vendor networks, and ensure strict compliance with RBI guidelines.

Key Responsibilities:

1. Strategy & Framework Development:

• Design Fraud Risk Frameworks: Formulate and implement comprehensive fraud control policies, standard operating procedures (SOPs), and risk mitigation strategies tailored to the NBFC landscape.
• Fraud Policy Governance: Continuously review and update fraud policies to adapt to emerging market threats, digital lending vulnerabilities, and evolving regulatory mandates.

2. Fraud Detection & Analytics:

• Implement Tech-Driven Solutions: Champion the integration of advanced fraud detection systems, AI/ML-driven analytics, and early warning systems (EWS) to identify suspicious patterns in loan sourcing, underwriting, and collections.
• Portfolio Monitoring: Monitor portfolio trends, perform root-cause analysis on early delinquencies (First Payment Defaults/Non-Starters), and identify systemic loopholes.
• Database Management: Oversee the utilization of negative databases and industry-shared platforms (e.g., Experian Hunter, CIBIL) to flag fraudulent applications at the pre-sourcing stage.

3. Investigations & Incident Management:

• Lead Investigations: Direct high-level digital and field investigations into suspected fraud rings, internal collusion, identity theft, and document forgery.
• Legal Action & Recovery: Liaise directly with law enforcement agencies (Police, Cyber Cell, EOW) and legal teams to file FIRs, pursue legal action against fraudsters, and maximize the recovery of compromised assets.

4. Internal Investigations, Vigilance & Disciplinary Process:

• Vigilance Oversight: Act as the vigilance point of contact for suspected employee misconduct, internal collusion, and policy violations, coordinating with the Internal Vigilance/CVO function (where constituted) on classification, referral, and closure of cases in line with the vigilance framework.
• Case Referral & Evidence Packs: Build fact-based investigation reports and evidence packs (transaction trails, digital forensics, geo-tags, statements) for cases warranting disciplinary or legal action, ensuring chain-of-custody and evidentiary integrity for use in Internal Committee proceedings.
• Partnering with P&C on Disciplinary Proceedings: Work jointly with People & Culture (HR) and the relevant Business Head to constitute Internal Committees/Disciplinary Committees for employee fraud, conduct breaches, or policy violations, and to determine charge-sheets, show-cause notices, and proportionate action (warning, suspension, recovery, or termination) in line with the HR Conduct & Discipline Policy.
• Disciplinary Committee Participation & Decisioning: Represent FCU as a standing member on Disciplinary Committee/Internal Committee meetings, presenting investigation findings and fraud-risk implications to support consistent, defensible, and audit-ready decisions, and ensure outcomes are documented and closed within defined TAT.
• Whistleblower & Protected Disclosure Linkage: Coordinate with the Ethics/Whistleblower helpline and Protected Disclosure (PIDA) mechanism to ensure independent handling of internal complaints, escalating cases involving senior management or conflicts of interest directly to the Audit Committee.
• Sanctions Tracking & Deterrence: Maintain a repository of substantiated internal fraud/misconduct cases, disciplinary outcomes, and blacklisting/debarment status (employees, DSAs, vendors), and publish periodic vigilance MIS to the CRO, RMC, and Board.

5. RCU (Risk Control Unit) & Vendor Management:

• Vendor Empanelment: Oversee the empanelment, training, and performance monitoring of external RCU agencies responsible for background checks, field investigations (FI), and document verifications (e.g., KYC, financial statements).
• SLA & Quality Control: Enforce strict Service Level Agreements (SLAs) with vendors, conduct regular audits of vendor activities, and ensure high-quality, unbiased reporting.

6. Regulatory Compliance & Board Reporting:

• RBI Compliance: Ensure absolute adherence to the Reserve Bank of India (RBI) guidelines regarding fraud reporting, including the timely filing of Fraud Monitoring Returns (FMR).
• MIS & Dashboards: Prepare and present detailed fraud risk metrics, incident reports, and mitigation plans to the Risk Management Committee (RMC) and the Board of Directors.

7. Stakeholder Collaboration & Team Leadership:

• Cross-Functional Synergy: Act as a trusted advisor to the Credit, Sales, Operations, and Underwriting teams, ensuring fraud controls are seamlessly embedded without severely impacting business turnaround times (TAT).
• Disciplinary Governance Partnership: Partner with People & Culture and Business leadership on the design and periodic review of the Internal/Disciplinary Committee framework, ensuring fraud and vigilance considerations are embedded in HR conduct policies and that case adjudication is consistent, proportionate, and audit-ready.
• Culture of Awareness: Drive fraud awareness and prevention training programs for internal employees and external sourcing channels (DSAs/Partners).
• Team Mentorship: Lead, mentor, and scale a high-performing team of regional FCU managers, analysts, and investigators.

Qualifications & Experience:

• Education: Bachelor's or Master's degree in Finance, Business, Criminology, or a related field.
• Professional Certification: Certified Fraud Examiner (CFE) or equivalent certifications in Risk/Fraud Management are highly preferred.
• Experience: 12 to 15+ years of extensive experience in fraud control, risk management, or RCU operations within the Retail Banking or NBFC sector.
• A minimum of 5+ years in a senior leadership or functional head capacity.
• Product Knowledge: Deep understanding of NBFC lending products.

Core Competencies & Skills:

• Analytical Acumen: Ability to dissect complex data sets, identify hidden anomalies, and leverage data analytics tools for fraud prediction.
• Investigative Expertise: Proven track record of managing end-to-end forensic investigations and interacting with law enforcement authorities.
• Tech-Savviness: Proficiency in digital lending fraud controls, identity verification APIs, and modern lending CRMs/LOS (Loan Origination Systems).
• Vigilance & Employee Relations Acumen: Working knowledge of employee conduct and disciplinary frameworks, with demonstrated experience partnering with HR/P&C and Business on Internal Committee proceedings and case adjudication.
• Crisis Management: Calm under pressure with strong decision-making skills during high-stakes fraud incidents or institutional crises.
• Leadership & Integrity: Unquestionable ethical standards, with the ability to lead by example and foster a culture of zero tolerance for fraud.