Overall purpose of role
The India Head of PBWM Compliance will report to the APAC Head of PBWM Compliance and Head of BBPLC India Compliance. This is an India regulated role under SEBI. The role holder has regulatory oversight responsibility of India PBWM Compliance.
Key Accountabilities
Business and other advisory, communication and escalation:
- Lead the PBWM India Compliance team in providing compliance activities in line with the Target Operating Model
- Support India PBWM CEO to manage compliance risks within appetite, review and approval of new products and oversight of annual compliance risk assessments.
- Represent PBWM India Business Oversight Compliance in key business and control governance forum, and pro-actively check and challenge conduct and regulatory risks.
- Provide day to day advice and check and challenge the business on all relevant matters including escalating significant matters promptly, providing additional information where requested, analysing/interpreting legal, regulatory and internal policy/procedure issues.
- Implementation of new regulatory initiatives, develop and create written policies and procedures to ensure compliance with applicable regulations, communicate regulatory requirements to the Business and conduct training where applicable.
- Input into the development and maintenance of the compliance risk framework, policies and supporting standards, to ensure compliance with relevant regulatory requirements under SEBI and RBI;
- Ensure local regulatory requirements over and above Barclays Policies and Standards are identified, documented and applied.
- Provide compliance advice and oversight for strategic investments and business growth initiatives.
- Work with other Risk disciplines, Internal Audit and Compliance Assurance to identify and evaluate the effectiveness of controls.
- Proactively lead the enhancement of the local compliance culture in the entity through a range of methods, including attendance at local business/other team meetings, training, engagement with local risk management, control, operations and front office functions and identification of and sharing of best practices.
- Managing regulatory compliance issues covering Investment advisory, Research ,PMS, AIF regulations governed by SEBI, including other banking and credit regulations governed by RBI.
Regulatory and other authority liaison:
- Liaise with and act as the point of contact for local regulators and local law enforcement agencies to resolve issues, including responding to requests for information.
- Managing regulators’ visits, audits and inspections.
- Work with Legal and Regulatory relations in responding to consultation papers or lobby for policy change
Verification Checks and Assurance oversight:
- Develop an annual verification check plan to deliver desk reviews over key conduct risks or regulatory concerns
- Ensure that there is a robust monitoring and oversight in place to verify the effectiveness of controls, policies and procedures as they relate to the local business, using both local and central resources.
- Work closely with the Compliance Assurance team to identify areas which require enhanced monitoring and testing.
- Work with local business(es) to address issues identified.
Governance
- Maintain regular communication/liaison with APAC Head of PBWM Compliance and BBPLC Compliance India, relevant senior management, business and others to ensure that they are aware of the business and regulatory risks, including advising them of significant policy matters, regulatory changes, audits and inspections and breaches, if any.
- Support periodic regulatory examinations and respond to regulatory inquiries and investigations
- Act as key contact point for Compliance issues for Barclays Internal Audit reviews.
- Implement robust management reporting processes on all regulatory and policy matters internally, within PBWM and to regulatory bodies, to ensure timely submission of regular and ad-hoc MI (including but not restricted to conduct risk MI) and input to Region, London, and to all local/other Compliance, Board or Committee reporting.
Stakeholder Management and Leadership
The nature of the role requires the role holder to have a demonstrated ability to work effectively across a broad range of stakeholder in terms of seniority and role profile. Positively engaging with and influencing stakeholders at Regional ExCo is an important and key aspect of the role.
Decision-making and Problem Solving
The role holder will have experience of:
- Solving problems with consideration of the broader risk management ecosystem.
- Ability to evaluate complex requirements and apply judgement in determining materiality and path forward.
Person Specification
- At least 15 years' experience in Compliance (or relevant areas in Legal, Audit or Control) with line management responsibilities
- In-depth knowledge and understanding of the regulatory requirements in India across the functional areas.
- Robust understanding of the various products and services offered by the Private Bank business cluster including Stock broking, Depository participant, Investments and Asset management (PMS/AIF/ Investment Advisory/ Research) businesses and Banking and Credit businesses.
- Understanding of SEBI and RBI regulatory environment will be preferred
- Understanding of Gity city regulations will be preferred
- Ability to work closely with other functions to find both technical and procedural solutions.
- Quick thinker with ability to understand complex transactions and explain compliance issues clearly and concisely.
- Ability to take independent decisions and guide business as well as to handle areas of difference with business and escalate.
- Detail oriented, strong team player with a proven track record
- Experience advising, engaging and influencing Executive Management on Compliance risk matters.
- Drives to high standards and seeks out opportunities to innovate and enhance.
- Experience overseeing performance, issues and related risks of services.
- Experience managing, leading, and developing a high-quality team of Compliance professionals.
- Experience leading and implementing the digitization of business and Compliance processes.
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Essential Skills/Basic Qualifications:
- Seasoned Compliance professional with comprehensive experience in the industry and of the India regulatory environment (specially SEBI)
- Collaborative with strong communication skills. Ability to make sound decisions and respond to issues promptly
- Experience of working with stakeholders at ExCo level.
- Experience of developing and delivering strategy and business plans for a region.
- Strong leadership and stakeholder management skills. Experience of leading in a matrix organisational structure
- Strong partnering, influencing and collaboration with stakeholders.
- Fluent in English, with strong written and oral communication skills particularly as relates matters of law and regulation and how they apply to business and client matters.
Desirable skills/Preferred Qualifications:
- The candidate will ideally have a degree level education and academic track record.
- Professional qualifications, certifications and/or registrations relevant to the Compliance roles.
Purpose of the role
To provide data-led expert oversight and check and challenge on business and compliance matters to evidence that the organisation is operating in a compliance with Barclays legal, regulatory and ethical responsibilities.
Accountabilities
- Identification and assessment of compliance risks through thorough reviews of business activities, changes, processes, testing and systems to.
- Identification and investigation of potential market abuse, including but not limited to, Insider Dealing, Unlawful Disclosure, Market Manipulation or Anti-Competitive Conduct.
- Conduct investigation of compliance risk events or breaches. Oversight and check and challenge of corrective actions and preventative measures to avoid future occurrences.
- Implementation of compliance policies and procedures in line with regulatory requirements and ensuring that the bank’s internal policies are aligned with international standards, including jurisdictional requirements.
- Collaboration with 1LOD, other relevant Compliance teams and legal, and relevant risk management functions to facilitate a comprehensive approach to compliance and risk management.
- Identification, investigation and oversight of potential money laundering, terrorist financing or other financial crime.
Director Expectations
- To manage a business function, providing significant input to function wide strategic initiatives. Contribute to and influence policy and procedures for the function and plan, manage and consult on multiple complex and critical strategic projects, which may be business wide..
- They manage the direction of a large team or sub-function, leading other people managers and embedding a performance culture aligned to the values of the business. Or for an individual contributor, they lead organisation wide projects and act as deep technical expert and thought leader, identifying new ways of working and collaborating cross functionally. They will train, guide and coach less experienced specialists and provide information affecting long term profits, organisational risks and strategic decisions..
- Provide expert advice to senior functional management and committees to influence decisions made outside of own function, offering significant input to function wide strategic initiatives.
- Manage, coordinate and enable resourcing, budgeting and policy creation for a significant sub-function.
- Escalates breaches of policies / procedure appropriately.
- Foster and guide compliance, ensure regulations are observed that relevant processes in place to facilitate adherence.
- Focus on the external environment, regulators, or advocacy groups to both monitor and influence on behalf of Barclays, when appropriate.
- Demonstrate extensive knowledge of how the function integrates with the business division / Group to achieve the overall business objectives.
- Maintain broad and comprehensive knowledge of industry theories and practices within own discipline alongside up-to-date relevant sector / functional knowledge, and insight into external market developments / initiatives.
- Use interpretative thinking and advanced analytical skills to solve problems and design solutions in often complex/ sensitive situations.
- Exercise management authority to make significant decisions and certain strategic decisions or recommendations within own area.
- Negotiate with and influence stakeholders at a senior level both internally and externally.
- Act as principal contact point for key clients and counterparts in other functions/ businesses divisions.
- Mandated as a spokesperson for the function and business division.
All Senior Leaders are expected to demonstrate a clear set of leadership behaviours to create an environment for colleagues to thrive and deliver to a consistently excellent standard. The four LEAD behaviours are: L – Listen and be authentic, E – Energise and inspire, A – Align across the enterprise, D – Develop others.
All colleagues will be expected to demonstrate the Barclays Values of Respect, Integrity, Service, Excellence and Stewardship – our moral compass, helping us do what we believe is right. They will also be expected to demonstrate the Barclays Mindset – to Empower, Challenge and Drive – the operating manual for how we behave.