Unit Head

Basic Function

Oversight on the Critical Case Unit (CCU) deliverables covering: (i) compliance with Freeze Order, Provisional Asset Preservation Order (PAPO), and Asset Preservation Order (APO); (ii) adherence with AMLC/regulators' requests for information and documents; and (iii) management of AML-adverse news.

Functional Responsibilities

A. Management of High-Profile Cases

• Supervises the management of high-profile cases, including clients involved in money laundering predicate crimes.
• Performs investigation and research on the case.
• Coordinates with various units and branches to probe relationship and transaction history, including alerts generated, if any.
• Performs Enhanced Due Diligence (EDD).
• Files warranted Suspicious Transaction Reports (STRs) or recommends No Suspicious Transaction Report (NSTR), as applicable.
• Performs fund tracing.
• Collaborates with Legal.
• Handles internal and regulatory reporting or escalation, as applicable.
• Monitors development of the case and apprises the heads.
• Handles documentation and record management, including coordination for Negative List Database System (NLDS) uploading.

B. Implementation of Court Orders

• Oversees the implementation of Court Orders, such as Freeze Orders, Provisional Asset Preservation Orders (PAPO), and Asset Preservation Orders (APO), and coordinates with business units and branches to implement the court orders within the prescribed period.
• Coordinates with business units and branches on asset freezing.
• Performs EDD and files warranted STRs or NSTR recommendation.
• Performs fund tracing and establishes related and materially linked accounts.
• Files returns within 24 hours based on documented freezing of accounts or funds.
• Coordinates with Legal.
• Coordinates for NLDS uploading.
• Handles documentation and record management, including NLDS upload coordination.

C. Handling of AMLC Requests

• Oversees the handling of AMLC requests to inquire into or examine bank deposits and investments, as well as requests for Know Your Customer documents and other AML-related transaction documents relevant to Mutual Legal Assistance Treaty (MLAT), within the prescribed timeline.
• Coordinates with business units and branches on submission of information and documentation requirements.
• Performs EDD and files warranted STRs.
• Performs fund tracing.
• Coordinates with regulators if an extension is needed to submit requirements.
• Confers with Legal, as applicable.
• Coordinates for NLDS uploading.
• Handles documentation and record management.

D. Handling of ML/TF News and Related Functions

• Superintends the handling of ML/TF news and related functions.
• Conducts adverse news checking based on internal arrangements.
• Files warranted STRs or NSTR recommendation.
• Coordinates for NLDS uploading.
• Handles documentation and record management.

E. Liaison Between the Bank and the AMLC

• Builds rapport with the AMLC.
• Attends meetings.
• Submits hard copy requirements.
• Handles enforcement procedures, as applicable.
• Addresses other concerns and requirements.

F. BSP Examination and Internal Audit Review Requirements

• Manages requirements during BSP Examination and Internal Audit Review.
• Submits or presents documents.
• Conducts walk-throughs.
• Handles communication and coordination.
• Crafts replies to AREF/ROE and IAD findings, as applicable.

G. Support to AML Department Head and Chief Compliance Officer

• Supports the AML Department Head and/or the Chief Compliance Officer in ML/TF/PF risk management.
• Prepares BAC and AMLCom materials pertinent to CCU.
• Assists in drafting replies, comments, and correspondences.
• Escalates significant concerns.
• Reviews and enhances policies and procedures and implements the same.
• Performs other ad hoc tasks or assistance.

H. Other Functions

Performs other functions that may be assigned as the need arises.