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JOB PURPOSE AND SUMMARY The Senior Manager, Risk and Beneficial Ownership is AMLSD’s senior internal management and technical coordination role, operating under the direction and authority of the Director, AMLSD. The position is responsible for managing AML/CFT/CFP risk-based supervision, supervisory analytics and beneficial ownership functions, translating the Director’s strategy and priorities into coordinated work programmes, methodologies, management information and operational delivery. The post-holder serves as the Director’s principal internal technical and managerial resource for risk-based supervision, supervisory prioritisation and beneficial ownership monitoring, supporting implementation of the FATF Standards and Mutual Evaluation readiness. By providing leadership and oversight of these internal functions, the role enables the Director to focus on strategic leadership, policy development, stakeholder engagement, national and international coordination, and other external-facing responsibilities. The position operates within approved laws, delegations and governance arrangements and does not assume statutory powers assigned to other authorised decision-makers.
Key Accountabilities
- Strategic Leadership and Management
- Manage the day-to-day operation of the AML/CFT/CFP Risk and Beneficial Ownership function under the AMLSD
- Director’s strategic direction, including delivery of its approved work programme, priorities, procedures, resources and performance reporting.
- Provide the Director, AMLSD with timely, evidence-based advice on material ML/TF/PF risks, supervisory priorities, beneficial ownership vulnerabilities, emerging trends, delivery risks and options for regulatory response.
- Translate the AMLSD Director’s strategy, decisions and Commission-wide AML/CFT/CFP priorities into measurable risk-based supervision and beneficial ownership work plans, and report implementation progress, barriers and material variances to the Director.
- Promote clear functional separation between risk intelligence and planning activities and the operational delivery of examinations, compliance reviews and enforcement actions, while ensuring effective coordination between those functions.
- Manage assigned staff, consultants and technical workstreams; allocate work; monitor deadlines; review outputs; and address capacity or quality concerns.
- Prepare concise decision-support reports, dashboards and recommendations for the Director’s review and, where authorised, support their presentation to senior management, relevant committees and the Board.
FINANCIAL SERVICES COMMISSION | AMLSD
Senior Manager, Risk and Beneficial Ownership | Job Specification & Description
- Oversee the development and controlled implementation of procedures, methodologies and quality controls for the function, and submit policies and material methodological changes to the Director for approval or onward approval through the appropriate governance channel.
- Risk-Based Supervision Framework
- Manage the implementation, maintenance, validation and enhancement of the Commission’s AML/CFT/CFP Risk-Based Supervision framework under the AMLSD Director’s strategic oversight.
- Develop and maintain transparent, documented and auditable sector and entity risk assessment methodologies, risk-rating models, weighting criteria, indicators and supervisory scoring tools.
- Ensure risk methodologies consider relevant inherent risk, control effectiveness and residual risk factors and are applied consistently across supervised sectors.
- Oversee sectoral, thematic and institutional AML/CFT/CPF risk assessments and ensure conclusions are supported by reliable evidence and documented rationale.
- Maintain current risk profiles for supervised entities and sectors, including documented triggers for reassessment and escalation.
- Identify emerging risks, vulnerabilities, typologies, data-quality concerns and supervisory blind spots and recommend proportionate responses.
- Coordinate periodic review and testing of the AML/CFT/CFP RBS methodology and document any changes, limitations, overrides or management decisions.
- Supervisory Analytics, Intelligence and Planning
- Lead analysis of annual returns, quarterly returns and other supervisory information and convert the results into risk assessments, supervisory intelligence and planning outputs.
- Integrate, where lawfully available, intelligence, examination findings, compliance review results, enforcement
- history, sanctions information, beneficial ownership data, audit findings and other relevant sources into supervisory risk analysis.
- Develop and maintain risk-based supervisory plans, entity prioritisation recommendations and examination scheduling inputs in coordination with supervisory operations.
- Maintain management dashboards, key risk indicators, coverage measures, action logs and implementation trackers.
- Produce periodic reports identifying high-risk entities, sector trends, material changes, concentration risks, data limitations and recommended supervisory action.
- Ensure that data definitions, calculations, assumptions and source records are documented and that material analytical outputs are reproducible and auditable.
- Coordinate the development, testing and responsible use of automated risk-monitoring, data-integration and reporting tools, with appropriate human review and quality assurance.
- Beneficial Ownership Assurance, Intelligence and Monitoring
- Manage AMLSD’s beneficial ownership assurance, intelligence, risk assessment, discrepancy management and effectiveness-monitoring programme under the Director’s oversight.
- Oversee risk-based reviews of beneficial ownership information, identity evidence, ownership structures and control arrangements for relevant legal persons and populations.
- Ensure enhanced analysis is undertaken where complexity, opacity, nominees, jurisdictional exposure, sanctions concerns, identity anomalies, adverse information or other documented triggers are present.
- Oversee the identification, triage, investigation, referral, correction tracking, escalation and closure of beneficial ownership discrepancies.
- Ensure beneficial ownership intelligence is converted into relevant supervisory referrals, risk-profile updates, off-site reviews, examination priorities, outreach or enforcement consideration.
- Develop and maintain beneficial ownership risk indicators, review criteria, case outcomes, quality controls and management information.
- Maintain management dashboards, key risk indicators, coverage measures, action logs and implementation trackers.
- Produce periodic reports identifying high-risk entities, sector trends, material changes, concentration risks, data limitations and recommended supervisory action.
- Ensure that data definitions, calculations, assumptions and source records are documented and that material analytical outputs are reproducible and auditable.
- Coordinate the development, testing and responsible use of automated risk-monitoring, data-integration and reporting tools, with appropriate human review and quality assurance.
- Beneficial Ownership Assurance, Intelligence and Monitoring
- Manage AMLSD’s beneficial ownership assurance, intelligence, risk assessment, discrepancy management and effectiveness-monitoring programme under the Director’s oversight.
- Oversee risk-based reviews of beneficial ownership information, identity evidence, ownership structures and control arrangements for relevant legal persons and populations.
- Ensure enhanced analysis is undertaken where complexity, opacity, nominees, jurisdictional exposure, sanctions concerns, identity anomalies, adverse information or other documented triggers are present.
- Oversee the identification, triage, investigation, referral, correction tracking, escalation and closure of beneficial ownership discrepancies.
- Ensure beneficial ownership intelligence is converted into relevant supervisory referrals, risk-profile updates, off-site reviews, examination priorities, outreach or enforcement consideration.
- Develop and maintain beneficial ownership risk indicators, review criteria, case outcomes, quality controls and management information.
- Oversee the analysis of monthly Registry intelligence reports and named-entity schedules and ensure actions
and outcomes are recorded.
- Maintain central evidence supporting Recommendation 24 and Immediate Outcome 5, including cases,
referrals, corrections, interventions, outcomes and effectiveness measures.
- Maintain clear boundaries between AMLSD assurance and analytical responsibilities and the Registry’s
statutory registration, record-maintenance and Registry enforcement functions
Financial Sanctions and Ownership/Control Screening Oversight
- Oversee the translation of authorised Financial Sanctions Notices into risk-based searches and ownership and control analysis for relevant Registry and supervisory populations.
- Ensure direct and indirect ownership and control are considered in accordance with applicable legal tests, guidance and approved procedures.
- Ensure screening alerts are documented, independently reviewed, dispositioned and escalated through authorised channels.
- Coordinate urgent or specifically approved screening activity within confirmed capacity and ensure recurring or population-wide screening is not undertaken without approved staffing, systems access, technology and quality controls.
- Maintain sanctions-related risk indicators, search records, alert evidence, escalation records and outcome tracking.
- Mutual Evaluation, Effectiveness and Strategic Reporting
- Coordinate AMLSD’s internal preparation and evidence collation for FATF and CFATF mutual evaluations, follow-up processes and related effectiveness assessments, under the Director’s strategic leadership and external representation.
- Maintain evidence demonstrating how risk understanding informs supervisory prioritisation and how beneficial ownership information produces measurable regulatory outcomes.
- Prepare and coordinate technical input for the Director’s review for national and sectoral risk assessments, effectiveness reports, Cabinet or Government briefings, AMLC submissions and other authorised strategic reports.
- Benchmark the Commission’s RBS and beneficial ownership practices against applicable international standards and relevant peer-jurisdiction approaches.
- Ensure claims in strategic or effectiveness reporting are mapped to supporting records, registers, case files, dashboards or other verifiable evidence.
- Governance, Quality Assurance and Staff Development
- Establish maker-checker, technical review and escalation arrangements for material risk assessments, beneficial ownership cases, sanctions alerts and management reports.
- Review routine analytical products within approved delegations and submit material, high-risk, novel, externally sensitive or strategically significant matters to the Director for decision, approval or further direction.
- Develop procedures, manuals, templates, guidance and training materials for RBS, supervisory analytics and beneficial ownership monitoring.
- Provide coaching, technical supervision and structured development to assigned staff and identify capability or resource gaps.
- Promote consistent evidence standards, version control, data integrity, confidentiality, audit trails and secure recordkeeping.
- Coordinate with Legal, IT, the Companies Registry, other FSC supervisory departments and competent
- authorities on matters within the role’s mandate.
ROLE POSITIONING AND GOVERNANCE
- The Director retains strategic leadership of AMLSD, accountability for departmental direction, and primary responsibility for executive, Board, Government, inter-agency, stakeholder and international engagement.
- The Senior Manager is the Director’s principal internal management and technical coordination support for the functions assigned to the position and does not operate as a parallel or independent authority within AMLSD.
- The Senior Manager coordinates day-to-day implementation, staff delivery, technical quality, management information and escalation so that the Director can maintain strategic and external focus.
- Departmental priorities, material risk positions, external policy positions, high-risk recommendations and significant changes to methodology or resource allocation must be referred to the Director for approval or direction.
- The Senior Manager must keep the Director appropriately informed through agreed reporting, escalation and decision-support arrangements and must not make material external commitments on behalf of AMLSD or the Commission without authority.
DECISION-MAKING AND AUTHORITY
- Access information and systems authorised for the performance of assigned duties, subject to confidentiality, data-protection and access-control requirements.
- Assign and review work within the Risk and Beneficial Ownership function and approve routine technical outputs within delegated authority.
- Request information, clarification, extracts or analysis through authorised internal and external channels.
- Recommend entity and sector risk ratings, supervisory priorities, enhanced reviews, examinations, remediation, referrals or enforcement consideration.
- Escalate material discrepancies, possible sanctions matches, unresolved ownership/control concerns, significant data-quality failures and barriers to timely access to beneficial ownership information.
- Represent AMLSD primarily in approved internal and technical forums. Participation in inter-agency, stakeholder, Government or international forums must be at the Director’s request or under an express delegation, with material positions and commitments cleared by the Director.
- Sign routine internal or external correspondence and reports only where formally delegated by the Director or other authorised decision-maker. The role may not establish Commission policy, make external commitments, or take binding regulatory, statutory, enforcement, inter-agency or high-risk decisions unless expressly authorised.
Application Deadline: October 16, 2026
Compensation: $79,178.00