Manager - Customer Due Diligence & Sanctions

Job Purpose: To support the MLRO function in executing Mashreq Digital Bank Pakistan’s Sanctions, KYC and Name Screening framework by reviewing alerts, conducting investigations, and ensuring compliance with SBP AML/CFT/CPF Regulations and Mashreq Group standards.

Key Result Areas

Risk Mitigation

• Review and approve onboarding, periodic KYC reviews, trigger reviews, and Enhanced Due Diligence (EDD) assessments for Retail, High-Net-Worth Individuals (HNWI), SME, and Business Banking customers in line with regulatory and internal requirements.

• Perform second-level review and disposition of Name Screening, Transaction Screening, and local list screening alerts, ensuring appropriate escalation of potential sanctions matches.

• Review customer risk ratings and determine appropriate due diligence requirements for high-risk customers, including PEPs, high-risk industries, high-risk jurisdictions, and complex ownership structures.

• Provide guidance and approval support to Business, Operations, and Compliance teams on KYC/CDD requirements, onboarding decisions, sanctions screening matters, and customer risk assessments.

• Review and challenge investigations conducted by analysts to ensure completeness, accuracy, consistency, and regulatory compliance.

• Ensure timely completion of onboarding reviews, KYC remediation, periodic reviews, and sanctions screening alerts within defined SLAs.

• Identify AML/CFT, sanctions, and customer due diligence risks and recommend appropriate mitigating controls.

• Support implementation and enhancement of sanctions screening controls, customer risk assessment methodologies, and KYC review processes.

• Oversee local sanctions list management activities, including validation of sanctions list updates and system configurations.

• Ensure customer records, screening evidence, and KYC documentation are maintained in accordance with SBP AML/CFT/CPF Regulations and Mashreq Group standards.

Processes

• Review and approve customer onboarding, periodic KYC reviews, trigger reviews, remediation cases, and EDD assessments in accordance with approved policies, procedures, and delegated authorities.
• Conduct risk-based assessment of customer profiles, ownership structures, source of funds/source of wealth information, and customer activities to determine appropriateness of onboarding and ongoing relationships.
• Review and disposition Name Screening, Transaction Screening, and adverse media alerts, ensuring timely escalation of potential sanctions matches or regulatory concerns.
• Perform quality assurance reviews of analyst investigations and KYC assessments to ensure consistency, completeness, and compliance with internal standards.
• Support sanctions list management activities, screening parameter reviews, and User Acceptance Testing (UAT) for system enhancements and regulatory change implementation.
• Identify emerging sanctions, AML, and customer due diligence risks and recommend enhancements to screening controls, risk rating methodologies, and onboarding processes.
• Ensure accurate maintenance of customer due diligence records, screening evidence, approvals, and audit trails within designated systems.
• Prepare management information, exception reporting, trend analysis, and regulatory submissions relating to sanctions, onboarding, and customer due diligence activities.

Governance

• Ensure adherence to SBP AML/CFT/CPF Regulations, Mashreq Group AML Standards, KYC Standards, and Sanctions Policies.
• Support regulatory inspections, internal audits, compliance reviews, and remediation initiatives relating to sanctions, onboarding, and customer due diligence controls.
• Conduct thematic reviews and root cause analysis of recurring onboarding, KYC, screening, and sanctions-related issues to identify control enhancements.
• Track and report sanctions, customer due diligence, and regulatory compliance issues to Compliance Management.
• Contribute to policy, procedure, and SOP development relating to KYC, sanctions screening, and customer risk management.
• Support training and awareness initiatives for Business and Operations teams on AML/CFT, KYC/CDD, and sanctions compliance requirements.
• Prepare MIS, management reporting, and trend analysis on customer onboarding, KYC reviews, EDD activities, and sanctions screening outcomes.

Knowledge, Skills and Experience

Behavioral Skills

• Strong analytical thinking and risk assessment capabilities.

• Excellent decision-making skills with the ability to exercise sound judgment on complex KYC, CDD, EDD, and sanctions-related matters.

• Ability to manage multiple priorities and work effectively under pressure while meeting regulatory and business deadlines.
• Strong stakeholder management and interpersonal skills, with the ability to challenge and influence business decisions where required.
• Excellent written and verbal communication skills, including the ability to articulate regulatory and compliance requirements to non-compliance stakeholders.
• High level of integrity, attention to detail, and professional skepticism.

Technical Competencies

• Strong knowledge of AML/CFT/CPF requirements, customer due diligence (CDD), enhanced due diligence (EDD), customer risk assessment, and sanctions compliance.
• Good understanding of SBP AML/CFT/CPF Regulations and international best practices relating to customer onboarding and sanctions compliance.
• Experience in reviewing and approving onboarding, KYC remediation, periodic reviews, and EDD assessments for Individual, SME, and Business Banking customers.
• Strong understanding of sanctions regimes and screening requirements, including UN, OFAC, EU, UK HMT, and local sanctions/proscribed lists.
• Hands-on experience with Name Screening, Transaction Screening, sanctions list management, and case management systems.
• Ability to assess sanctions, AML, and reputational risks and recommend appropriate risk mitigation measures.
• Experience in performing quality assurance reviews, root cause analysis, and process improvement initiatives.
• Strong report writing, investigation documentation, and management information (MIS) preparation skills.

Experience

• Master's degree in Finance, Business Administration, Economics, Accounting, Law, or a related discipline.
• ACAMS, CGSS, ICA, or equivalent AML/Sanctions certification preferred.
• Minimum 6–8 years of experience in AML/CFT Compliance, KYC/CDD, EDD, Customer Risk Assessment, and Sanctions Screening.
• Proven Compliance experience in reviewing and approving onboarding and periodic KYC reviews for Individual and SME/Business Banking customers.