Principal Financial Crime Officer

The purpose of the Principal Financial Crime Officer is to provide advanced advisory, oversight, and technical expertise on the full spectrum of financial crime compliance, including anti-money laundering, combating the financing of terrorism, sanctions compliance, fraud prevention and fulfilling the Section 42A of the FIC Amendment Act role of ensuring the effectiveness of the Financial Crime stream. The role plays a key part in designing, implementing, and refining systems and controls across due diligence and reporting. It supports the integration of a risk-based approach to financial crime governance, strengthens awareness across the DBSA, and contributes to meeting both domestic and international regulatory obligations. This role contributes to safeguarding the DBSA’s integrity, reputation, and regulatory standing through strong financial crime prevention and detection capability.

Key Responsibilities

1. Strategic Financial Crime Focus

• Contribute to the development and implementation of a financial crime compliance strategy to manage and mitigate financial crime risks, including AML, fraud prevention, and sanctions compliance.
• Develop risk-based financial crime policies, procedures, and control frameworks to ensure appropriate controls are in place.
• Integrate financial crime risk into broader compliance monitoring plans and governance framework.
• Foster a culture of compliance and ethical conduct within the organisation by promoting awareness and understanding of financial crime risks among employees.
• Continuously review and enhance the financial crime framework, technologies and methodologies to reflect changes in regulatory expectations and emerging risks.

2. Lead Advisory and Oversight of Financial Crime Compliance

• Provide expert guidance on financial crime legislation, regulatory expectations, and institutional obligations.
• Support implementation of a risk-based financial crime compliance framework across business units.
• Advise on high-risk clients, transactions, geographies, and sectors requiring enhanced controls or approvals.
• Provide input and support to group and divisional compliance initiatives.
• Verify that all financial crime activities are undertaken for all areas and projects of the DBSA.
• Partner with relevant stakeholders across the Bank to effectively manage financial crime risk.

3. Financial Crime Risk Assessment

• Perform regular Bankwide risk assessments to identify potential financial crime risks within the organisation.
• Evaluate the effectiveness of existing controls and develop continuous improvement processes and frameworks across the Bank’s business units and operations.
• Present risk assessment reports to senior management and the Board, highlighting key findings and recommendations.
• Provide insights and advice on high-risk clients, transactions, geographies, and sectors requiring enhanced due diligence, monitoring, or escalation.

4. Drive Know Your Customer (KYC) and Enhanced Due Diligence

• Provide oversight of client onboarding and ongoing due diligence, applying a risk-based approach.
• Lead complex enhanced due diligence reviews and recommend mitigations for clients with heightened financial crime risk.
• Advise on appropriate documentation, verification, and ongoing monitoring standards.

5. Monitoring and Assessing Anti-Money Laundering (AML) and Sanctions Controls

• Execute anti-money laundering activities, transaction reviews, and analysis of suspicious indicators.
• Conduct screening processes for politically exposed persons, sanctions, and watchlists.
• Work with internal teams to respond to alerts, investigate anomalies, and escalate suspicious activity reports.
• Interact with internal and external bodies to identify and manage financial crime risk.

6. Communication and Awareness Initiatives

• Design and deliver financial crime training programmes tailored to the needs of the Bank.
• Promote a culture of compliance and ethical behaviour across the Bank.
• Manage the review of training content and regularly update to reflect regulatory changes and emerging threats.
• Approve and facilitate training and awareness initiatives to strengthen staff understanding of financial crime risks and promote a strong culture of compliance across the institution.

7. Governance and Reporting

• Review and respond to regulatory queries, internal audits, or ethics-related investigations relating to financial crime.
• Lead the preparation of submissions to compliance and risk management committees from a financial crime perspective.
• Implement corrective actions and drive continuous improvement in financial crime controls.
• Maintain audit readiness through regular self-assessments and control testing.
• Oversee compliance with financial crime legislation, regulatory expectations, and institutional obligations relating to anti-money laundering (AML) and sanctions compliance.
• Analyse trends and patterns in financial crimes and integrate findings into the broader compliance monitoring framework and governance processes.
• Prepare and present financial crime compliance submissions, reports, and insights to relevant compliance, risk, and governance committees to support informed decision-making.
• Draft internal reports, regulatory returns, and risk committee inputs to anti-money laundering and sanctions compliance.

8. Stakeholder Management

• Partner with internal stakeholders across the Bank to identify, assess, and manage financial crime risks in line with regulatory and governance requirements.
• Liaise with external regulators, law enforcement, and industry bodies as required.
• Represent the bank in financial crime forums and working groups to align expectations, gather insights, and ensure successful outcomes.

9. People Management

• Lead, mentor, and develop a high-performing team, fostering a culture of collaboration, accountability, and continuous learning to maximise individual and collective potential.
• Drive talent development initiatives, including coaching, performance management, and career pathing, to build and retain a skilled and motivated team.
• Provide direction and management to the Division, to enable strategy execution.
• Attract, retain, develop talent and ensure succession planning and sufficient capacity and capability in all critical functions, supporting diversity strategies and initiatives as well.
• Promote DBSA values and a culture of high performance through implementing performance management in line with the planned strategic objectives, goals, quality standards and agreed key performance measures using sound performance management principles.
• Contribute to building synergies & cooperation across functions in the DBSA.

Key Measurements of Outputs

• Effectiveness and coverage of financial crime risk assessments, including timely identification and mitigation of key risks.
• Accuracy and completeness of politically exposed persons screening, know your client documentation, and enhanced due diligence reports.
• Accuracy and efficiency of AML screening and transaction monitoring, including the number of suspicious activity reports (SARs) filed and false positive rates.
• Compliance rate with KYC/CDD requirements, including completion of periodic reviews and updates of customer risk profiles.
• Quality and timeliness of financial crime reporting to senior management, governance committees, and regulators.
• Audit readiness and outcomes, including the number of audit findings and the effectiveness of corrective actions implemented.
• Training coverage and effectiveness, measured by completion rates and post-training assessment scores across business units.
• Level of digital enablement in financial crime controls, including automation of monitoring systems and adoption of analytics tools.
• Management of team performance, talent development, and succession planning using the performance management system.

Expertise & Technical Competencies

a) Analytical Thinking

• Identifies multiple elements of a problem and breaks down each of those elements in detail, showing causal relationships between them.
• Uses several analytical techniques to identify several solutions and weighs the value of each.

b) Attention to Detail

• Monitors the quality of others' work.
• Checks to see that procedures are followed by others.
• Keeps clear details records of own and/or other activities.

c) Integrity

• Is willing to end a business relationship because it was associated with unethical business practices.
• Is capable of challenging senior management (in an appropriate manner) in order to act on espoused values.

d) Decisiveness

• Makes timely decisions about complex issues even when some information is missing.
• Makes decisions and stands by them even when they are controversial or unpopular.
• Grasps critical business opportunities when they arise by making timely decisions.

e) Information Seeking and Analysis

• Analyses relationships among several parts of a problem or situation.
• Anticipates obstacles and thinks ahead about next steps in detail.

f) Customer Service Orientation

• Tries to understand the underlying needs of customers and matches these needs to available or customised products and services.
• Adapts processes and procedures to meet ongoing customer needs.
• Utilises the feedback received by customers to develop new and/or improve existing services/products that relate to their ongoing needs.
• Thinks of new ways to align DBSA’s offerings with future customer needs.

Minimum Qualification

• A Postgraduate Degree in Law, LLB, Compliance, Forensic Accounting, Risk Management.
• A certification in anti-money laundering or financial crime prevention.
• Accredited or certified member of the Compliance Institute of Southern Africa (CISA).

Minimum Experience

• A minimum of 10 years of relevant experience in financial crime risk management, anti-money laundering, sanctions compliance, and forensic auditing.
• Demonstrated ability to apply regulatory requirements in a financial or development finance institution.
• Experience in conducting transaction monitoring, drafting reports, and engaging with regulators.
• Experience managing interactions with the Financial Intelligence Centre, law enforcement, or prudential regulators.
• Practical exposure to screening systems, transaction monitoring tools, and client risk rating models.

Desirable Requirements

• Familiarity with public sector and developmental finance regulatory frameworks and infrastructure-specific risks.

Required Personal Attributes

a) Risk Response and Reporting

• Develop and implement appropriate risk mitigation for significant and unusual risks to which the business is exposed.
• Provide advice on business continuity management mechanisms, define appropriate risk responses for reasonably foreseeable emergency scenarios and events.
• Design and implement risk reporting systems and communicate to executive management risk processes and results, including recommendations for improvement.

b) Project Management

• Initiates project plans and secures resources for projects that span area or department boundaries.
• Uses estimating techniques and develops project risk management approaches.
• Has an in-depth and practical understanding of how to maximise the effectiveness of project teams.

c) Financial Crime Management

• The skills, knowledge, and abilities necessary to detect, prevent, and respond to financial crimes.
• Deep understanding of financial crime regulatory frameworks.

d) Solution Focus

• Identifies complex problems based on a broad range of factors, many of which are ambiguous or difficult to define.
• While remaining guided by organisational values, identifies optimal solutions, thinking first in terms of possible approaches and flexibilities in the system vs. blind adherence to rules or procedures.
• Evaluates the effectiveness and efficiency of solutions after they have been implemented and identifies needed changes.

e) Compliance Risk Management

• Establishing and embedding FIC Awareness in the DBSA and its Business Units.
• Identify and assess regulatory universes and draft compliance risk management plans for high-risk legislation.
• Interact with internal and external bodies such as Risk Management, Internal Audit, Legal Services, Regulators and Industry Bodies to identify and manage compliance risk.
• Oversee the implementation of compliance with Financial Crime management practices for allocated portfolios.
• Facilitates financial crime assessments and monitors priority compliance matters across the Organisation.
• Ensure that there are sufficient compliance execution capabilities within the Organisation.
• Provide input and support to group and divisional compliance initiatives.
• Coordinate and ensure maintenance of the compliance universe.
• Effectively contribute to reducing the compliance risk exposure of the Bank.
• Ensure that Fina Crime compliance activities are undertaken for all areas and projects of the Bank.
• Partner with relevant Stakeholders within the Divisions to effectively manage risk.
• Re-engineer business processes to be fully compliant with legislation.

f) Compliance Risk Monitoring

• Compiles Business Unit-specific plan that ensures that the Business Units comply with the applicable legislative requirements and regulations.
• Compiles submissions to relevant Regulators.
• Reviews and monitors compliance processes and compliance with regulations and legislation.
• Establishes processes to identify instances of noncompliance and reports on non-compliance and any process deviations to senior management.
• Reports as necessary to ensure that compliance risks are considered and dealt with effectively and in a timely manner. All risk reporting must be of the highest quality.
• Works with other risk officers to share information and ensure uniformity in compliance risk management approaches and mitigations.
• Monitors the external environment to determine emerging and unknown compliance risks, determine the impact on the Bank and facilitate communication to various Stakeholders.
• Reports on the status of compliance to the Head of Compliance in accordance with the compliance universe.

g) Development of Policies/Regulations

• Can develop advanced policies or regulations effectively with little supervision.
• Performs comparative analysis of policies to identify new policy requirements.
• Effectively obtains approval from senior managers or key stakeholders for new policies or regulations.
• Exercises independent judgment regarding the development of policies.
• Understands principles of compliance and regulations and provides guidance on operational compliance of policies and regulations.
• Enforces rather than oversees the regulatory role, with assistance from subordinates.

h) Detail Orientation

• Quickly identifies relevant and irrelevant information to support accurate decision making.
• Maps out all the logistics and details of a situation to ensure smooth and flawless implementation.
• Consistently identifies all relevant details that are not obvious in complex situations.
• Requires the highest standards for accuracy and quality for their work.
• Establishes processes to ensure accuracy and quality of services delivered by the team.

i) Written Communication

• Understands that different writing styles are required for different documents or audiences.
• Write effective correspondence, prepare questions and reports, statements of circumstance and briefing notes.
• Reviews others’ documents for clarity and impact.
• Has a solid mastery of writing principles such as grammar, sentence construction, etc.

j) Verbal Communication

• Able to communicate complex problems or concepts by making them simple and understandable for others.
• Adapts language to the level of the audience in order to ensure that the message has a positive impact and is interesting to the audience.
• Is articulate, demonstrates a wide range of vocabulary, and is confident when talking to large/high-level audiences.

k) Presentation Skills

• Can reinforce key presentation points with examples.
• Is able to translate technical terminology into language understandable to the audience.
• Has insight into the audience’s behaviour and motivation and responds appropriately and professionally, adapting communication style as appropriate.

*The KPA’s, competencies and relationships listed in this document are not exhaustive, and the incumbent will be expected to undertake additional duties within their capacity to meet the needs of business and/or the business unit.*