Amit Roy
Kuwait City
Summary
Have over 18 years in Financial Crime Risk (AML/Sanction/Anti Bribery & Corruption / Fraud Advisory) leadership role including 4 years in business, technology consulting and implementation of AML/Sanctions Screening Technology Systems with an overall 26 years of work experience. Experienced in setting up Financial Crimes Compliance frameworks that include creating and managing fully integrated sanctions screening compliance systems, CDD/EDD process and systems, Transaction Monitoring process and systems ending with SAR disclosure to the country’s authorities. Experience involves leading and managing multi-cultural teams spread across other countries and providing advisory support to 1LOD and product teams, conducting assessment of top and emerging risks and conducting gap analysis of new regulatory or legislative changes impacting Financial Crime, while coordinating and maintaining oversight of internal and external regulatory audits and regulatory inspections while supporting the Group’s strategic direction and growth aspirations. Experienced in conducting Financial Crime Compliance trainings, conducting AML/Sanctions technology system evaluation, system implementation and calibration, business. Have extensive FCR culture embedding experience in implementing Global Standards, Operational Effectiveness Exercise and FC Risk Steward Maturity framework setting up experience in Kuwait while working with cross cultural 1LOD and 2LOD teams in Kuwait and across the Region.
Overview
22
22
years of professional experience
1
1
Certification
Work History
Head of Financial Crime Compliance & MLRO
HSBC Middle East – Kuwait Branch
2021.09 - Current
- Develop and maintain Bank’s Anti-Money Laundering and Counter-Terrorist Financing and Proliferation Financing policy implementation in line with evolving global, regional and country statutory and regulatory obligations
- Action ongoing reviews and reporting as MLRO (Money Laundering Reporting Officer) for the Bank to meet regulatory obligations and manage financial crime risk covering money laundering, sanctions, bribery & corruption and fraud risks
- This also includes assisting top management in developing and maintaining effective Financial Crime framework and enhance improved compliance culture embeddedness.
- Monitoring money laundering, sanctions and fraud risks through intelligence based and review of customers lifecycle and transaction triggers, to maintain oversight of emerging patterns in criminal activity and investigation of all internal and external suspicious activity for submission of SAR to Reporting agency.
- Oversee review of effectiveness of money laundering compliance policies and procedures to manage and enhance anti-money laundering and sanctions screening typologies and its coverage
- Act as trusted point of contact for internal and external stakeholders (including government, regulators, law enforcement, banking association and FATF MER Assessors) for all financial crime risks including fraud risk mitigation
- Monitoring Financial Crime KCI’s and KRI’s covering all financial crime prevention and detection controls and systems while ensuring that firm's risk management policies, risk assessment profile, access to Materially Non-Public Information and its robust application are adequately documented and implemented
- Provide SME advice and solution to the Commercial Banking and Global Banking Businesses in Kuwait, on core banking compliance, review of general terms & conditions, review of FCR challenges on new product development and its due diligence and support the regulatory conduct teams on review of licensing and other business initiatives
- Provide FC advisory support during the process of onboarding clients and ongoing customer lifecycle, identification of material trigger events and FC support for deals, escalations to Regional RRCSC
- Ensure rapid adoption of remedial actions for deficiencies in policies, procedures, systems or controls and follow up on those recommendations that are self-identified or by Compliance Assurance or Internal Audit or during Regulatory examinations
- Manage annual review and ongoing maintenance of Bank’s Financial Crime policies including fraud standards while ensuring they are aligned with business requirements and meet applicable legal and regulatory obligations and enhancing compliance culture embeddedness and improving stronger relations with risk owners and control owners
- Work collaboratively with other Risk & Compliance team members in Kuwait and in the MENAT region to provide insight and subject matter expertise in mitigating reputational risk issues and stronger risk management, and internal control principles across the Bank for both internal and external stakeholders
- Ensure annual budgeting is met while managing costs, headcount and resources within Compliance FC function.
Head of AML, Sanctions, AB&C & MLRO
HSBC Middle East – Kuwait Branch
2016.01 - 2021.08
- Bank’s MLRO responsible for Suspicious Activity Report’s submission and compliance to KwFIU (Kuwait Financial Investigations Unit)
- Country Sanctions Officer for all UN Security Resolution, OFAC, HMT, EU, HKMA, Central Bank of Kuwait and MOFA (Ministry of Foreign Affairs) Production Order / Legal Enforcement Authorities orders, regulatory compliance actions for Kuwait including reporting obligations
- Regulatory Contact for Nazaha (Kuwait Anti-Corruption Authority) for all anti-corruption legal enforcement orders investigations and restriction actions
- Monitoring AML/Sanctions/AB&C compliance vulnerabilities, develop & implement corrective plans for resolution of such compliance issues & provide guidance on mitigation; Providing advisory support for Business line customer identification / acceptance / repudiation / termination programs, KYC, CDD & EDD for various commercial banking, lending, syndication, trade, securities and custody products
- Employee fraud investigations and escalation to Branch and Regional management; Provide SME advice and solution to Commercial Banking and Global Banking Businesses in Kuwait, on core banking compliance, new and ongoing product development and due diligence including FCR Due diligence process, support regulatory conduct teams on marketing materials reviews, licensing and other business initiatives
- This also includes provision of advice on general compliance issues including support liaison with Central Bank of Kuwait on operations of Corporate Banking business in Kuwait and planning how Compliance risks can be managed, operated
- Monitor and review departmental Annual budget plans including FTE (full Time Employee) resource job estimation, utilization, training and performance improvement planning
- Conduct on-going compliance monitoring activities and lead special projects as required;
Senior Manager – AML/CFT Unit
Gulf Bank K.S.C.P
2015.01 - 2015.12
- Reviewing and monitoring AML, KYC, automated sanctions screening and transaction monitoring policies & procedures & recommending updates to Head – AML /CFT for statutory & regulatory compliance; Ensuring adherence of Bank’s sanctions policies and procedures by evaluating close matches of international sanctions screening compliance referrals from Business Units / Branches related to customer on-boarding, SWIFT remittances, trade instruments are resolved within SLA; Lead serious and complex cases investigations and escalate Suspicious Activity Report’s on suspicious customer activities to the AML Head for onward reporting to the country FIU; Review of the Bank employee transactions including senior management and escalation to the Head AML/CFT Unit; Sampling and evaluating closure of alerts/cases and non-referral of potential cases to provide independent assurance that investigators are consistently meeting the Bank’s expectations; Working with second line Operational Risk members and reviewing quality standards
- Leading Bankwide / Branch / Business Unit Compliance assurance reviews & appraise processes for KYC CDD / EDD, international sanctions screening adequacy / violations including base benchmarking and subsequent reviews and tracking including comprehensive sample testing and re-testing to mitigate CBK compliance vulnerabilities; Reviewing AML risk assessment matrix and Bankwide compliance framework that includes risk assessment of customers, products, services and transactions channels for categorization of these parameters during a customer’s life cycle in the Bank’s risk assessment and transaction systems; Identify and review potential concerns and control issues, determine the root cause of issues and ensure stakeholders develop and implement appropriate corrective actions; Assist AML Head in implementing & reviewing Anti-Money Laundering / Combating Financing of Terrorism and Financial Crime compliance program to ensure compliance with all prevailing local & international laws and regulations; Act as Single Point of Contact for escalated internal, correspondent banking enquiries, external and CBK compliance audit reviews and assist in resolution of the audit issues;
Manager – AML/CFT Unit
Gulf Bank K.S.C.P
2009.03 - 2014.12
- Ensuring international sanctions screening compliance referrals from Business Units / Branches related to customer on-boarding, SWIFT remittances, trade instruments are resolved within SLA; Investigate serious cases and create Suspicious Activity Report’s on suspicious customer activities to the AML Head for onward reporting
- Implemented Bank wide AML/Sanctions risk assessment, sanctions name screening / customer suspicious transactions monitoring/reporting systems that included RFP writing, setting up of evaluation criteria, evaluate vendor Product Walk Through, lead business process re-engineering including SWIFT payments, lead techno-functional gap analysis, project management, lead data quality assessment, UAT including writing of procedural documentation for the entire Bank across multiple functions including front office, Trade Finance, Operations including SWIFT payments, cheque clearing functions; Conducting and reviewing ML compliance control gaps & strengthening AML/Sanctions compliance controls in commercial banking and trade related products
- Identifying / reporting /tracking AML/Sanctions compliance vulnerabilities & violations, develop & implement corrective plans for resolution of such compliance issues & provide guidance on mitigation; Leading Bankwide / Branch / Business Unit Compliance assurance reviews & appraise processes for KYC CDD / EDD, international sanctions screening adequacy / vulnerabilities / violations including base benchmarking and subsequent reviews and tracking including comprehensive sample testing and re-testing to mitigate CBK compliance vulnerabilities; Lead and act as a techno-functional lead for implementation of the automated international sanctions / AML transaction surveillance systems / reporting / business intelligence tools in the Bank.
Regional Manager – Middle East
3i Infotech Ltd, Bahrain
2008.05 - 2009.02
- Involved in business analysis and business consulting on risk assessment, SWIFT Message screening and transaction monitoring typologies and procedural implementation and product design related to AML technology products in the BFSI (Banking, Financial Services and Insurance) vertical for AMLOCK across multiple geographies in Bahrain, Qatar, Kuwait and Sudan; Achievement included business analysis of Bank wide AML program prior to implementation of the anti-money laundering technology program in the largest Bank in a GCC country.
Regional Manager – Bahrain & Mumbai
Kiya.ai (previously Infrasoft Technologies Ltd)
2003.07 - 2008.05
- Involved in assisting in design of Bank wide AML program, creation and review of risk assessment metrices, recommendation and fine tuning of international sanctions screening, SWIFT payment message monitoring, transaction monitoring typologies and procedural implementation including anti money laundering technology systems consulting to regulators and clients; Achievement included business analysis and consulting of the AML program in the implementation of the anti money laundering technology program in one of the large regional banks in Bahrain, top four Banks in Nigeria, community banks in Kenya and one of the largest community bank in India; Involved in pre-sales, business analysis and consulting, product design related to AML technology products in the BFSI (Banking, Financial Services and Insurance) vertical across multiple geographies and FI segments in Kuwait, Bahrain, Qatar, UAE, Jordan, Turkey, Kenya, Ghana, Nigeria, South Africa and India.
Regional Manager – Mumbai
Prakriti Technologies
2002.06 - 2003.06
- Have successfully identified and established partner relationships in India, Europe and Middle East and acquired marquee clients in the financial services, consumer durables verticals.
Education
Masters in Business Administration -
University of Pune
Pune, India01.1992
Bachelor of Computer Science -
University of Pune
Pune, India01.1990
Skills
- Strong team-builder
- Strategic leadership
- Goal-oriented
- Analytical
- Approachable
Certification
- Association of Certified Anti Money Laundering Specialists Certification, 07/2010, CAMS License - 162251
- International Diploma in AML, 05/2014, International Compliance Association, UK and Manchester Business School
Technology Skills
- Business Objects Web Intelligence XI Reports (Intermediate)
- Tonbeller Siron AML 10.3 (Advanced)
- Tonbeller Siron Embargo 10.3 (Advanced)
- Tonbeller Siron KYC 10.3 (Intermediate)
- Tonbeller Siron GL (Intermediate)
- AMLOCK 2.11 (Intermediate)
- OMNIEnterprise AML 2.3 (Intermediate)
- Visio (Intermediate)
Timeline
Head of Financial Crime Compliance & MLRO
HSBC Middle East – Kuwait Branch
2021.09 - Current
Head of AML, Sanctions, AB&C & MLRO
HSBC Middle East – Kuwait Branch
2016.01 - 2021.08
Senior Manager – AML/CFT Unit
Gulf Bank K.S.C.P
2015.01 - 2015.12
Manager – AML/CFT Unit
Gulf Bank K.S.C.P
2009.03 - 2014.12
Regional Manager – Middle East
3i Infotech Ltd, Bahrain
2008.05 - 2009.02
Regional Manager – Bahrain & Mumbai
Kiya.ai (previously Infrasoft Technologies Ltd)
2003.07 - 2008.05
Regional Manager – Mumbai
Prakriti Technologies
2002.06 - 2003.06
Masters in Business Administration -
University of Pune
Bachelor of Computer Science -
University of Pune
- Association of Certified Anti Money Laundering Specialists Certification, 07/2010, CAMS License - 162251
- International Diploma in AML, 05/2014, International Compliance Association, UK and Manchester Business School
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