AML/CTF, Financial Sanctions, FATCA, CRS, GDPR

9/2017 – 6/2018

 Regulatory mapping and counselling of MB and branches concerning EU regulations and guidelines, national laws as well as guidelines and circulars of Financial Market Authorities
 Advice of MB and branches on a broad range of areas such as AML/CTF, Compliance (FATCA, CRS, Registry of Accounts) and Internal Controls as well as legal matters like capital increase etc.
 Support of MB with the statement concerning the final audit report of the Austrian National Bank and setting up a remediation plan
 Preparation and conduct of the on-site visit of Financial Market Authority Austria and Portugal of the branch in Portugal
 Lead of projects: implementation of 4th AML Directive, GDPR and PSD II and a new IT-tool for PEP-, sanctions- and transactions monitoring, outsourcing
 Regular review and adaptation of policies and procedures concerning AML/CTF, FATCA, CRS, Account Registry and Compliance (e.g. New Product Approval Process, Remuneration Policy, Outsourcing Policy, Fit & Proper Policy etc.)
 Streamlining of internal processes (e.g. PEP-, sanctions- and transactions-monitoring, outsourcing) and guidance of the AML/CTF Officers in the branches
 Coordination and cooperation with state authorities of Austria and the branches as well as lawyers, consultants and external auditors
 Regular reports to internal and external stakeholders

Risikomanagement (Finan.)

1/2014 – 8/2017

 Advice on legal and compliance matters concerning AML/CTF, KYC, Financial Sanctions, FATCA, CRS and Registry of Accounts
 Projects: Outsourcing of transactions monitoring to the Servicing Center, implementation of technical requirements as well as processes and policies concerning Capital Outflow, Registry of Accounts, Common Reporting Standard and 4th Anti-Money Laundering Directive
 Responsibility for monitoring, review and analysis of legal and regulatory developments, updating policies and procedures and regular training of the employees (face-to-face-training or web-based-training)
 Implementation of new processes or streamlining existing processes in close cooperation with business lines in order to establish best practice approaches (e.g. online-credit, video-identification, identification through qualified third parties)
 Annual risk assessement considering the range of products, customers, regions and transactions
 Conduct of internal investigations concerning customers and transactions and filing Suspicious Activity Reports with the Austrian Financial Intelligence Unit
 Support and regular training of AML Officers of connected banks in Lower Austria
 Regular reports to MB, Financial Market Authority Austria and further internal and external stakeholders
 Coordination and cooperation with external consultants, lawyers, Financial Market Authority Austria and other state organisations
 Planning and organising human ressources within the department (14 employees) and implementation of efficient processes

Risikomanagement (Finan.)

7/2011 – 12/2013

 Support of the MB and the customer relationship managers concerning legal and compliance issues
 Responsibility for ongoing compliance training and policy reviews
 Coordination and cooperation with external consultants and authorities
 Legal support of the implementation of online banking and implementation of adequate processes in sight of Compliance, AML and CTF

Rechtsberatung