Senior Manager - KYC Advisory

JOB PURPOSE

• The Senior Manager – KYC Advisory is responsible for providing expert, risk-based Know Your Customer (KYC), Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) advisory, independent challenge and customer financial crime risk oversight across the Bank.
• The role ensures that complex and high-risk customer relationships are appropriately assessed, that beneficial ownership and customer risk-rating standards are robust, and that customer financial crime risks are managed within the Bank’s risk appetite, while First Line retains ownership of due diligence execution.

KEY RESPONSIBILITIES

• Lead independent specialist advice on complex customer onboarding, retention, high-risk relationships and financial crime risk acceptance.
• Challenge First Line due diligence for PEPs, high-risk jurisdictions, adverse media, source of funds and wealth, and complex customer structures.
• Advise on beneficial ownership and control tests, trusts, nominees, layered structures and escalation of opaque arrangements.
• Oversee the customer risk-rating methodology, risk factors, overrides and alignment with the Business-Wide Risk Assessment (BWRA) and risk appetite.
• Oversee periodic and event-driven review standards, KYC deficiencies and escalation arrangements.
• Provide technical input into KYC policies, digital onboarding, risk-rating tools, UBO capture and remediation programmes.
• Report material customer risks and advisory themes to Management and governance forums.
• Lead, develop and allocate resources across the KYC Advisory team.

KEY ACCOUNTABILITIES

• Provide timely, documented and risk-based advisory opinions on complex and high-risk customer relationships.
• Ensure CDD and EDD standards for PEPs, high-risk jurisdictions, high-risk sectors, correspondent relationships and complex structures are robust and consistently applied.
• Challenge the adequacy of source of funds and source of wealth assessments, adverse media analysis and risk mitigation measures.
• Ensure beneficial ownership is identified and verified in line with the Companies Act, POCAMLA and CBK requirements, and escalate opaque arrangements.
• Oversee the customer risk-rating methodology, including risk factors, weightings, overrides and alignment with the BWRA.
• Provide Second Line input into high-risk customer acceptance and exit decisions within delegated authority.
• Oversee periodic and event-driven review standards and monitor the status of overdue reviews and KYC deficiencies.
• Provide technical input into KYC policies, procedures, digital onboarding journeys and new product approvals.
• Support KYC remediation programmes and validate the adequacy of remediation standards.
• Identify recurring KYC control weaknesses and themes, and ensure remediation is owned by accountable First Line functions.
• Escalate material customer financial crime risks and unresolved disagreements to the MLRO and Senior Management.
• Prepare MI on advisory volumes, high-risk customer populations, KYC deficiencies and emerging risk themes.
• Support regulatory inspections, audits and correspondent bank due diligence requests.
• Lead, mentor and develop the team, including performance management, capability building and succession planning.

Qualifications

CORE COMPETENCIES AND SKILLS

• Strong knowledge of AML/CFT/CPF laws, CBK Prudential Guidelines, FATF Standards and beneficial ownership requirements.
• Expertise in CDD, EDD, PEP assessment, source of funds and wealth analysis, and customer risk assessment.
• Strong understanding of complex legal structures, trusts, nominee arrangements and corporate ownership.
• Strong understanding of banking products, customer segments and financial crime typologies.
• Ability to provide clear, practical and defensible risk-based advice.
• Excellent report writing, Board reporting and executive communication skills.
• Strong stakeholder engagement, influencing and constructive challenge capability.
• Demonstrated leadership, people management and team development skills.
• High integrity, independence, sound judgement and decision-making capability.

 EXPERIENCE

• Minimum 10 years’ experience in AML/CFT/CPF, KYC, Financial Crime Compliance, Risk or Internal Audit within the financial services sector.
• At least 5 years’ experience in a management role.
• Demonstrated experience advising on complex onboarding, high-risk relationships, PEPs and beneficial ownership.
• Experience with customer risk-rating methodologies, KYC remediation and regulatory inspections.
• Prior experience in a Tier 1 bank and familiarity with CBK and FRC supervisory expectations will be an added advantage

ACADEMIC AND PROFESSIONAL QUALIFICATIONS

• Bachelor’s degree in Law, Finance, Banking, Commerce, Accounting, Economics, Risk Management or a related field.
• Master’s degree in a relevant discipline will be an added advantage.
• Professional certifications such as CAMS, ICA Diploma in AML, ICA Certificate in KYC and CDD, CFE, CPA(K), ACCA or equivalent.
• Demonstrated commitment to continuous professional development in AML/CFT/CPF and customer due diligence.