The Captive Risk and Compliance Officer within the Commercial Bank Risk department is responsible for managing compliance risk for the Commercial Bank Risk department and the Cayman Islands Branch to ensure compliance with all US and Cayman Islands laws, rules and regulations including Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), Proliferation Financing (PF), International Financial Sanctions, Common Reporting Standards (CRS), Foreign Account Tax Compliance (FATCA), as well as the US Bank Secrecy Act (BSA) and all Bank policies.
- Own and manage the regulatory and compliance risk for the Global & Captive Insurance Group and the Cayman Islands Branch. This includes monitoring the adequacy, effectiveness and adherence of day to day compliance with all applicable US and Cayman Islands legislation including the Bank Secrecy Act, Banks and Trust Companies Law, the Monetary Authority Law, Proceeds of Crime Law, Anti-Money Laundering Regulations as well as other applicable legislation, Bank policies and accepted standards of best practices.
- Work closely with Comerica's AML, Compliance and Business Unit Risk Groups to minimize risk and ensure compliance with all Bank policies and procedures including OFAC, Politically Exposed Persons (PEP), Suspicious Activity Reporting and International Sanctions. Complete risk assessments.
- Make sure customer files are properly documented with all required account opening checklists and questionnaires, customer identification, beneficial ownership forms, registers of directors and members, etc.
- Complete required supplier Third Party Risk Reviews and requests; Work with Tax Compliance area and KPMG to ensure Common Reporting Standards (CRS) forms are properly filed for offshore accounts every year with the Cayman Monetary Authority.
- Act as point person on all audits including internal audits, Cayman Islands or US regulatory exams, AQR, critical spreadsheet self-audits, etc.
- Complete quarterly Regulatory Reporting Certification for Captive Insurance - Favorable Collateral (RC-R) Report.
- Coordinate with Corporate Legal, Institutional Trust, and Financial Reporting to make sure all Cayman regulatory requests (e.g. financial reports, dormant accounts, SIBL, BTCL, Economic Substance, Inherent Risk Control, etc.) are accurately and timely filed on the Cayman Monetary Authority's on-line portal and all fees are paid.
- Educate and train business unit on risks that affect them.
- Ensure Business Continuity Plan fully encompasses all critical business process needs and recommend changes where required.
- Manage Cayman Branch relationship with CIBC Bank and Trust (Cayman) Limited, our registered agent.
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