Head of Financial Crimes Compliance for UAE and Qatar

Job Title: Head of Financial Crimes Compliance for UAE and Qatar

Corporate Title: Up to Director

Location: Dubai

Company Overview:

At Bank of America, we are guided by a common purpose to help make financial lives better through the power of every connection. We do this by driving Responsible Growth and delivering for our clients, teammates, communities and shareholders every day.

Being a Great Place to Work and providing a culture of caring is core to how we drive Responsible Growth. We are intentional about fostering an inclusive workplace where every teammate has the opportunity to succeed, build a career and contribute to our shared success. This includes attracting and developing exceptional talent, recognizing and rewarding performance, and supporting our teammates’ physical, emotional, and financial wellness through affordable, competitive and flexible benefits.

We value the unique perspectives individuals bring from all backgrounds and career paths - whether shaped by military service, community college education, or a wide range of work and life experiences. These journeys foster resilience, leadership and innovation, strengthening our workforce and positively impact the communities we serve.

Bank of America is committed to an in-office culture that supports collaboration, engagement, and career development. Our approach includes clear in-office expectations, while providing an appropriate level of flexibility based on role-specific responsibilities and business needs.

At Bank of America, you can build a successful career with opportunities to learn, grow, and make an impact. Join us!

This role will serve as the Head of Financial Crimes Compliance covering the UAE and Qatar. Bank of America Merrill Lynch’s business in the region is across the Global Banking and Markets space including a Dubai-based Equities desk, investment banking, corporate banking and transaction banking. The individual will serve as the Money Laundering Reporting Officer (MLRO) for Dubai and Qatar regulated entities as well as being responsible for delivering the global financial crimes compliance framework in the region.

Responsibilities

• Oversee compliance with obligations outlined within local Financial Crimes (Anti-Money Laundering/Counter Terrorist Financing, Economic Sanctions, and Anti-Bribery/Anti-Corruption) laws, rules, and regulations.

• Oversee implementation of Financial Crimes requirements defined by the GFC Financial Crimes Programme, in coordination with appropriate GFC Regional Executive.

• Determine actions required to ensure MLI DIFC & QFC Branches have met specific regulatory provisions around Financial Crimes laws and regulations.

• Discharge any specific money laundering reporting officer duties required by local laws, rules, or guidance.

• Receive and act upon any relevant findings, recommendations, guidance, directives, resolutions, sanctions, notices or other conclusions received from competent authorities.

• Act as the primary local point of contact for the Front Line Units on matters related to financial crime compliance.

• Act as the principal point of contact for in-country law enforcement and regulators relative to financial crimes prevention, detection, investigation and compliance.

• Engage, as appropriate, Branch and regional senior management on matters relating to Anti-Money Laundering, Economic Sanctions and Anti-Bribery/Anti-Corruption.

• In coordination with the appropriate GFC Regional Executive, engage relevant stakeholders for interpretation of laws, rules or guidance related to financial crimes.

• Maintain up-to-date knowledge of financial crimes compliance regulation and guidance internationally and monitor regulatory change and best practice in UAE/DIFC & Qatar/QFC.

• Keep the deputy MLRO informed of significant AML/CFT developments (whether internal or external) and work closely with local Compliance and Operational Risk.

Policies and Procedures

• Work with Front Line Units to design and implement local procedures consistent with the Financial Crimes Programme and help ensure their requirements are embedded within their procedures and controls.

• Coordinate with the appropriate regional GFC team members to ensure country specific requirements are adequately considered within global policy and procedures. 

• Identify and escalate to the appropriate GFC Regional Executive any conflicts between local law and GFC standards.

• Ensure Front Line Units adhere to policies, standards, procedures, laws and regulations.

• Ensure compliance with all applicable financial crimes standards such as those related to high risk jurisdictions and customer types requiring Enhanced Due Diligence to be in place.  Ensure appropriate approvals (as necessary) are in place, and any additional monitoring is conducted as required by local laws, regulations, or guidance.

• Ensure records pertaining to requirements of the Financial Crimes Programme (such as Customer Due Diligence / Enhanced Customer Due Diligence / Suspicious Activity Reports) are maintained and properly stored as required by global and country specific regulations. 

• Work with appropriate GFC Regional Executive to identify gaps in the Front Line Units’ GFC Programme implementation.  Provide Front Line Units oversight in fixing gaps identified in the GFC checklist.   

• Ensure that the applicable UAE & Qatar Financial Crimes Country Standards are in place, up to date and reflects all current laws, rules and regulations.

• Accountable for the management and oversight of Non-Financial Regulatory Reporting (NFRR) obligations, including the maintenance of NFRR procedures, regulatory reporting inventories, governance controls, and the submission of financial crime-related regulatory notifications to relevant authorities.

Training

• Lead the design, periodic review, enhancement, and delivery of risk-based AML/CFT and financial crime training programme.

• Collaborate with relevant stakeholders to identify MLI DIFC and MLI QFC Branch training needs.

• Provide or coordinate Financial Crimes training/education to staff as required by local policies, local laws or regulations.

• Ensure continued professional competence by undertaking relevant AML/CFT, sanctions, and financial crime training and maintaining compliance with DFSA continuing professional development requirements, including a minimum of 15 hours of CPD annually.

• Keep abreast of emerging financial crime risks, regulatory developments, enforcement actions, and industry best practices relevant to the MLRO role.

Investigations and Reporting

• Ensure that any potentially suspicious matters are being reported to the Company’s Financial Intelligence Unit via The Referral Management System (TRMS).

• Act as the single reference point within the Front Line Units to whom all employees are instructed to promptly refer matters potentially suspected of being connected with a financial crime. 

• Ensure that where investigations are undertaken into potentially suspicious matters the investigation is appropriately conducted and the rationale for the conclusion is well documented.

• Make any required suspicious activity filings to law enforcement or regulatory agencies within the timelines prescribed by local laws or regulations and in compliance with the Financial Crimes Policies and Standards.

• Keep systemic records within approved case management applications for all matters investigated (reported and not reported), including all internal findings and analysis.

• Responsible for any additional reporting requirements defined by law, rules, or guidance (e.g., Economic Sanctions reporting requirements).

Reporting to Senior Management

• Report potential financial crimes in region to the GFC Regional Executive as appropriate.

• Share information on financial crimes risks and issues with GFC senior leadership.

• Ensure that the oversight and management groups are informed of any local or international financial crimes regulatory changes. 

• Coordinate the sharing of suspicious activity information, as allowed for by law, for escalation and risk management purposes.

Monitoring and Testing

• Lead risk assessment activities for MLI DIFC & MLI QFC Branches regular annual risk assessments and ad hoc projects; ensure risk assessments are aligned to the Global Financial Crimes Compliance template and methodologies.

• Conduct and/or oversee Monitoring and Testing activities for the local jurisdiction to ensure required Financial Crimes controls are working effectively.

Regulatory Interaction and Interpretation of Regulations

• Develop a strong relationship with regulators, such as the DFSA & QFCRA.

• Deal with the DFSA/QFCRA in an open and co-operative manner and must disclose appropriately any information of which the DFSA/QFCRA would reasonably be expected to be notified.

• Act as the point of contact for competent U.A.E. and Qatar authorities and the DFSA/QFCRA regarding money laundering issues.

• Respond promptly to any request for information made by competent U.A.E. and Qatar authorities, the DFSA/QFCRA.

• Coordinate any local exams and engage GFC as required.

• Ensure prudential annual reports such as Annual AML Return is promptly filed in accordance with DFSA/QFCRA regulatory guidelines.

• Oversee the remediation of Regulator, Corporate Audit, or Self-Identified Audit Issues, and communicate status updates to senior management and regulators as appropriate.

People Leadership and Talent Development

• Provide day-to-day management, supervision, and development of local GFC personnel.

• Allocate responsibilities and oversee the execution of regulatory, governance, and financial crime compliance activities.

• Ensure staff maintain appropriate knowledge, skills, and training to effectively perform their roles.

• Provide guidance, challenge, and support to promote a strong culture of compliance and risk management.

Required Qualifications:

• Several years’ experience in a financial crime compliance role at an international financial services firm.

• Several years’ experience of managing financial crimes compliance risks in the Middle East.

• ACAMS or other relevant financial crime qualifications.

• Experience working directly with internal audit and regulators.

• Strong business knowledge of institutional products and services – particularly Markets and Banking.

• Experience managing executive business stakeholder relationships as well as challenging executive business leaders when needed.

• Team-oriented – able to partner with colleagues across the business, support function and compliance organizations

• Good oral and written communication skills

• Strong analytical skills; ability to communicate complex analysis to a variety of non-subject matter expert stakeholders.

• Proactive in terms of assessing opportunities for efficiency.

• Flexible – able to adapt to changes in the organization and business model with ease.

Skills that will help:

• Global Risk Management experience

Bank of America:

Good conduct and sound judgment is crucial to our long-term success. It’s important that all employees in the organisation understand the expected standards of conduct and how we manage conduct risk. Individual accountability and an ownership mind-set are the cornerstones of our Code of Conduct and are at the heart of managing risk well.

We are an equal opportunities employer and ensure that no applicant is subject to less favourable treatment on the grounds of sex, gender identity or gender reassignment, marital or civil partner status, race, religious or similar philosophical belief, political opinion, colour, nationality, ethnic or national origins, age, sexual orientation, pregnancy or maternity, socio-economic background, responsibility for dependants or physical or mental disability. The Bank selects candidates for interview based on their skills, qualifications and experience.

We strive to ensure that our recruitment processes are accessible for all candidates and encourage any candidates to tell us about any adjustment requirements.