Description
Job Title: Senior Manager - Market Conduct Risk Reports to: CRO Division: Risk Management Division Section/Unit: Market Conduct Risk UnitJob PurposeThe Senior Manager – Market Conduct Risk is responsible for establishing, maintaining and enhancing the Bank's independent Market Conduct Risk Framework as part of the Second Line of Defence, ensuring effective oversight of conduct risks across the Bank in accordance with the UAE Central Bank Consumer Protection Regulation, Consumer Protection Standards, Market Conduct Risk-Based Supervision Framework, SME Customer Protection Regulation and other applicable regulatory requirements.The role is responsible for providing independent challenge and oversight over the effectiveness of the First Line's management of conduct risks throughout the customer lifecycle, promoting fair customer outcomes, strengthening conduct culture, overseeing market conduct governance arrangements, assessing emerging conduct risks using a risk-based supervisory approach, and providing assurance and reporting to Senior Management, the Board and relevant Board Committees.The role also supports regulatory engagements, thematic reviews, conduct risk assessments and continuous enhancement of the Bank's conduct risk governance framework.Key AccountabilitiesGovernance and OversightEnsure the bank's conduct risk policy is reviewed regularly by senior management in accordance with regulatory requirementsDefine and communicate clear roles and responsibilities to operationalize consumer protection standards and conduct risk frameworksConduct oversight of functions owning and embedding Code of Conduct, Conflicts of Interest, Whistleblowing, ABC in line with Consumer Protection Standards and RegulationsDevelop, maintain and continuously enhance the Bank's Market Conduct Risk Framework, methodology, taxonomy and governance standardsEstablish a risk-based conduct supervision methodology covering all business lines, products, customer segments and distribution channelsEnsure conduct risk is appropriately integrated within the Bank's Enterprise Risk Management Framework and Risk Appetite FrameworkProvide independent oversight and challenge over First Line implementation of Consumer Protection Standards throughout the customer lifecycleOversee governance relating to Vulnerable Customers and Financial InclusionRisk AssessmentReview controls established by first-line owners to mitigate misconduct risks in third-party dealings; escalate gaps to senior managementEstablish, maintain and regularly review a risk register for misconduct risks across all business unitsPerform enterprise-wide conduct risk assessments using a risk-based supervisory methodologyIdentify inherent and residual conduct risks across products, services, channels and customer journeysConduct thematic reviews based on emerging risks, complaints, regulatory findings, incidents and market developmentsDevelop and maintain the Conduct Risk Universe and Conduct Risk RegisterRecommend enhancements to mitigate identified conduct risksConsumer Protection RegulationsIndependently oversee implementation of Consumer Protection Regulation and Consumer Protection StandardsChallenge effectiveness of customer disclosures, transparency and communicationsOversee product governance arrangements including target market assessments and product suitabilityReview fair value / Value for Money assessments for productsProvide oversight over customer onboarding, servicing, complaints, vulnerable customer treatment and account closuresChallenge the effectiveness of complaint root cause analysis and remediationProduct GovernanceIndependently challenge New Product Approval processes to ensure customer risks have been adequately assessedReview customer outcomes throughout the product lifecycleEnsure conduct risk assessments are completed before launch of new products or material product changesRegulatory EngagementLead Market Conduct regulatory engagements with CBUAECoordinate responses to regulatory examinationsTrack remediation plans arising from supervisory reviewsMonitor implementation of regulatory developmentsTalent ManagementAssess and enhance existing training programs on conduct risk, ensuring employees understand and comply with conduct standardsProvide input and oversight to ensure conduct risk considerations are incorporated into the HR performance evaluation frameworkMarket Abuse & IntegrityOversee reporting and escalation of market abuse incidents per insider trading policies, and challenge the adequacy of remedial actionsProvide oversight and input to Insider Trading policy and procedures to manage market abuse risks associated with the bank's customersConflicts of InterestProvide oversight and challenge on the bank's Conflict of Interest policy and controls; review and escalate significant conflicts to Senior ManagementCulture and PeopleCollaborate with product development and marketing teams to ensure the suitability and appropriateness of products and services for customersSpecialized Risk AreasCollusion Risk: Oversee risks of collusion between parties aimed at manipulating market conditionsConsumer Mobility Risk: Oversee risks related to consumer ease in switching providersCooling Off Risk: Ensure customers are provided with adequate cooling-off periodsSales, Marketing, Advertising, and Promotional Risk: Oversee risks associated with these activities, ensuring regulatory complianceSolicitation Risk: Oversee risks associated with solicitation practicesQualifications & ExperienceBachelor's degree in Business, Law, Education, or a related field3-5 years of experience in regulatory compliance, controls and governance within the banking industryStrong knowledge of regulatory compliance; excellent communication skillsAreas of CompetencyExcellent verbal and written communication skillsDeep knowledge of compliance standards, particularly those related to conduct risk and consumer protectionKnowledge of how conduct risk intersects with operational risk and ability to implement effective control measuresStrong skills in analysing data related to conduct risk incidents, customer complaints, and market abuse, and developing appropriate mitigation strategiesExperience working across compliance, legal, human resources, and business units to ensure alignment on conduct risk mattersExcellent communication skills to engage with internal stakeholders (senior management, business units) and external bodies (regulators, auditors) on conduct risk issues