Vice President - Financial Crime Compliance And Risk Compliance

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Role Purpose

The Business Need:

Global Research (“GR”) is a GBM business line operating consistently globally, managed centrally from London and via two additional hubs in Hong Kong and New York.Key operational considerations include:

·There are stringent rules pertaining to research production and distribution. Key areas include: i) the registration and licensing of publishing entities and individual analysts; ii) the simultaneous distribution of GR product to buyside institutional clients of our Markets business;iii) ensuring research operates independently from influence from investment banking and other ex-GR parties; iv) the non-front running of investment views, or creation of false markets, or advantaging certain clients over others, encouraging other to trade while in possession of material non-public information, and/ or trading on personal account inappropriately, among many other imperatives.While research rules tend to be stronger in some territorities (eg: the US, Hong Kong, Singapore, UK and the EU) than others, as our research goes to all such territories the same Global rules apply to all GR in all locations.

·Currently ASP GR RC matters are escalated from local RC compliance officers on a pure relationship basis to the Regional RC Research Compliance team in the Hong Kong hub.All training (new joiner, annual refresher and one off) on RC Research is provided from Hong Kong to all such staff in the region but there is limited capacity to either regularly visit these offices or conduct regular monitoring activities of a level experienced by GR staff in any of the Hubs (eg: Hong Kong).

·There is a clear business need to ensure a dedicated RC Research compliance advisor in available on the ground in Mumbai to supplement the existing Regional RC Research Compliance team in the HK hub

·There is renewed regulatory interest in Research issues stemming from local offices, as well as a significant increase in Indian Regulatory focus (as Research business is regulated activity under the SEBI) and it is critical to the GR franchise and wider HSBC brand that these risks are adequately understood and suitable managed.There have been recent, public, regulatory breaches resulting in significant fines by US regulators stemming from Research activities originating in the APAC region

Role Purpose:

The role forms a key part of the RC control infrastructure for the Global Research (“GR”) business line.

The role holder will undertake, with particular regard to GR operations in the Mumbai location(s), and with oversight and guidance provided by the Regional Head of RC GBM-Research, the following responsibilities: 

• chaperone certain calls and meetings involving GR and non-GR personnel,
• act as a gatekeeper for emails and certain other requests from GBM, CMB, PB, AMH, RBWM and other external parties,
• undertake research report conflict reviews, working predominantly with APAC Regional RC Research and Global Control Room teams, escalating all sensitive matters to the Regional Head of RC Research (Asia Pacific)
• assist the Regional RC Research team in managing the wall-crossing of GR personnel, vetting, and pre-deal report compliance due-diligence,
• implement and cascade policies, procedures and best practices for purposes of developing a compliance framework to govern research (i.e., what form and with what controls and internal permissions and sign-offs),
• establish and/or augment a monitoring program to ensure research is distributed within parameters and comply with established controls, escalating to the Regional Head of Research Compliance,
• provide training on research-related requirements, including new and existing regulations, Group Standards, Global Research policies and best practice
• monitor the status of compliance issues identified and reported by regulators, internal audit, risk management, Compliance Inspection and/or Research Compliance. Provide updates to the Regional Head of Research Compliance and assist the business on remediation and/or integration efforts,
• participate on conference/video calls for purposes of coordinating with the Regional Head of Research Compliance and other in-region Research Compliance Officers (as well as similar counterparts in other Regions) on all matters concerning research,
• ensure all the above activities are shared and communicated across the Global Research Compliance team structure for global alignment and consistency to all regions/line of business under Research Compliance and to help deliver the Annual Research Compliance plan objectives and priorities,
• complete certain compliance related initiatives, projects and ad-hoc reviews as well as assisting with the core APAC RC Research compliance team gatekeeping responsibilities

The role will involve occasional travel within India (Bangalore specifically), whilst maintaining a regular dialogue with existing non-GR local compliance officers in the focus territory.

Core Attributes

Impact on the Business/Function

·Proactive approach with respect to the ensuring all suitable research controls are in place, operational and understood.

Customers / Stakeholders

• Liaise with GR business and Compliance stakeholders predominantly within GBM adopting a solutions orientated approach but mindful of compliance and risk imperatives
  

Leadership & Teamwork

·Provide day-to-day and project management support on compliance-related matters and projects to ensure both progress toward a common goal in alignment with agreed timelines and firm standards.

·Work in close alignment with the Research Compliance, Regional and Global Teams, the Regional Head of RC Research, local territory LCO and the wider RC teams such as Global Control Room, and GBM compliance to deliver the Annual Research Compliance plan objectives and priorities

Operational Effectiveness & Control

·Maintains a proper level of awareness of regulatory changes impacting the business; ensures appropriate communication and development of policies, procedures and best practices.

·Maintains a current knowledge of compliance-related industry initiatives pertaining to areas of responsibility and best practices.

·Coordinates regulatory matters, including examinations, inquiries and investigations as it relates to research.

Manages and assists in drafting, editing and maintaining written policies, procedures and best practices.

Major Challenges

·Under an increasingly and heavily regulated environment, ensuring that the business line(s) is (are) compliant with all applicable laws, rules, and regulations.

·Operating efficiently and effectively under the pressure of business and compliance related deadlines.

·Business activity is being compliance and risk assessed properly and in a timely manner.

·Helping to ensure that the operation remains regulatory compliant as the business grows.

·Ensuring that the compliance officers covering the business as well as business management and their respective staffs are kept abreast of all applicable rules, regulations, best practices, and department requirements.

·Ensuring global awareness of issues faced and being part of a team defining and implementing globally-consistent strategies and solutions

Role Context

• Mid-level compliance officer with leadership qualities who has the ability to communicate in an effective manner
• Advise Global Compliance and Business staff on business-related matters and special projects/initiatives which must account for or consider regional/global regulations and industry best practices.
• Account for application of extra-territorial regulations on Business conducted in region.
• Sets priorities and makes day-to-day decisions, with guidance provided by the Regional Head of Research Compliance.
• Escalates matters to senior management as needed.
• Participation in industry and working group meetings.

Management of Risk

·Continually reassess the operational risks associated with the role and inherent in the business, taking account of changing economic or market conditions, legal and regulatory requirements, operating procedures and practices, management restructurings, and the impact of new technology.

·Ensure employees apply compliance and operational risk controls in accordance with HSBC and regulatory requirements, expectations, standards and policies.

·Optimizes relations with regulators by addressing any issues

• The jobholder will also adhere to and be able to demonstrate adherence to internal controls. This will be achieved by adherence to all relevant procedures, keeping appropriate records and, where appropriate, by the timely implementation of internal and external audit points, including issues raised by external regulators.

·The jobholder will implement the Group compliance policy by containing compliance risk in liaison with Global Head of Compliance, Global Compliance Officer, Area Compliance Officer or Local Compliance Officer. The term ‘compliance’ embraces all relevant financial services laws, rules and codes with which the business has to comply.

·This will be achieved by adhering to all relevant processes/procedures and by liaising with Compliance department about new business initiatives at the earliest opportunity. Also and when applicable, by ensuring adequate resources are in place and training is provided, fostering a compliance culture and optimising relations with regulators.

Role Dimensions

• Role operates within the RC – GBM, Global Research Compliance function.
• Reports functional directly to the Regional Head of RC, GBM-Research for ASP and for entity into Compliance Officer for HSCI.
• No direct reports
• Provides compliance support (as detailed in the Role Purpose section) to HSBC GBM businesses, predominantly Global Research, with significant direction and oversight provided by the Regional Head of RC-Research Compliance

#LI-HSBCRM

• Minimum Graduation or as required for the role, whichever is higher
• Experience dealing with core Research Compliance activities including standards for content, analyst conduct and an understanding of conflicts of interest surrounding the interaction of different businesses with research analysts.
• Understanding of the structure of research and experience with reviewing research reports for conflict of interest.
• Possesses leadership qualities and is a strategic thinker.
• Excellent communication and inter-personal skills, with experience dealing with employees at all levels and across country/regional borders, including the capacity to articulate the case for policy changes.
• Experience dealing with regulatory and internal control matters.
• Experience interpreting and analyzing a large volume of information and/or data and providing a succinct summary for management.
• Ability to lead change and influence Compliance colleagues to embrace new approaches for the production and review of research and other written materials.

Additional Information

·Mandatory to successfully complete Anti-Money Laundering and Sanctions training and post-course assessment, as required.

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