Hariharan Srinivasan

Roles and Responsibilities - Lead in Compliance-AML from June 2024 to present

• Analyzing customer transactions to detect potential money laundering activities using predefined detection scenarios from the SAS application. Leveraging systems such as Eagle-eye, Name Screening, Flex Cube, and Citrix BO.
• Completing due diligence on new-to-bank client onboarding and monitoring existing clients to rule out money laundering, terrorist financing, and sanctions risks. Reviewing KYC documentation to ensure compliance with AML/CFT and sanctions regulations.
• Conducting risk assessments on reviewed clients, advising on new account opening requests, and making decisions on the risk assessment of existing relationships.
• Investigating and reporting unusual/suspicious cases and further filing Suspicious Transaction Reports (STRs) to the UAE Central Bank portal and taking necessary actions to mitigate risks in the L2 investigations. Responsible for determining whether an activity is suspicious and requires reporting to the authorities, typically through escalation to the MLRO or their delegate. Ensuring prompt reporting of suspicious activities in line with applicable SLAs.
• Initiate Requests for Information (RFI) and referrals to Relationship Managers (RMs) to obtain clarifications and documents that justify transactions, ensuring a clear understanding of the rationale behind the transactions.
• Promptly responding to Compliance/AML-related queries from the UAE Central Bank, Head Office, and other regulators, as well as actively investigating and addressing concerns raised by internal stakeholders related to Unusual Activity Reports (UAR).
• Supporting the enhanced due diligence process for high-risk businesses prior to account openings or credit proposals. Ensuring the implementation of customer screening through World-Check, Name Screening, Accuity, and other negative lists.
• Reviewing and testing AML and sanctions systems, developing comprehensive user requirements and test cases, and identifying potential weaknesses. Assisting in system fixes to ensure effective compliance. Regularly suggesting and implementing improvements to detection scenarios to reduce false positives and enhance the identification of potential triggers.
• Drafting and reporting on MLRO/Deputy MLRO approved STRs. Managing freezing of funds, blocking of accounts, and responding to RFIs from other banks on anti-money laundering and sanctions matters. Reviewing and preparing responses to regulatory inquiries, ensuring accurate and comprehensive information is provided to law enforcement and Central Bank authorities.
• Managing and resolving escalations by providing guidance on complex cases, fostering a collaborative environment, and ensuring prompt and accurate solutions in alignment with regulatory expectations.
• De-risking flagged customers and managing exit strategies for high-risk accounts. Reviewing and analyzing actions and requests following AML-RRU standard operating procedures (SOPs), incorporating feedback from senior management and relevant authorities into daily operations.
• Engaging with relevant stakeholders as needed, including the complex and major investigations team, senior management, and customer exit management, to address and manage financial crime risk.

Roles and Responsibilities - Senior Associate in CTP till May 2024

• Customer Transactions Profiling (CTP) - Serving as the initial line of defense in identifying customers who have significantly breached their turnover.
• Customer Account Review - Ensuring alignment with customer KYC by reviewing customer accounts from a transaction profiling perspective. This includes undertaking updates to customer profiles/KYC as required from these reviews.
• KYC Scenario Review - Conducting reviews of KYC Scenarios/CTP alerts triggered in SAS/BPM to ensure timely and policy-compliant updates to customer KYC.
• RFI/Referrals - Initiating RFI/referrals to Relationship Managers (RM) to obtain clarifications/documents that justify transactions and understand the actual rationale for KYC breaches.
• Unusual Activity Reports (UARs) - Issuing UARs when suspicious activities are noted on customer accounts or declared KYC.
• Quality Assurance (QA) - Performing QA on other team members to enhance their quality of work and prevent external findings.
• Report Generation - Creating new reports to identify customers who are significantly breaching the turnover declared at the time of KYC. This is achieved by suggesting new scenarios/parameters with the assistance of the business intelligence unit.
• Risk Register Maintenance - Identifying and maintaining key risks of the business unit in the Risk Register using the bank’s internal tool (Blue Prism Application). Regular Risk Control Self-Assessments are performed to mitigate risks associated with our processes/procedures.
• Debit Freeze - As the first line of defense unit, placing customer accounts into debit freeze in case of non-responsiveness to raised KYC queries to prevent regulatory and compliance breaches.

Roles and Responsibilities:

• Evaluate transactions and customer relationships for money laundering activities and identify red flag issues and escalated within the AML group.
• Performing overall analysis and assessment of alerts / cases generated through DETICA, NORKOM 6.1 and MANTAS using internal external research tools such as ECM Accuity, World Check, Arachnys etc.
• Conducting research by using internal and external databases to compile a portfolio of information on various transactions types as ITT, OTT, Cheques & Fund transfers.
• Responsible for identifying (PEP, SDN & suspicious activity) and researching the patterns, trends and anomalies in complex transactions.