Position Description

Job Title: Senior Compliance Manager (Anti-Money Laundering & Sanctions Risk Management)

Reports To: Chief Compliance Officer

Department: Compliance

Type of work done by staff: 60% Specialist (Strategic, Legal & Regulatory); 40% Operational

Supervises: Internal External

• 01 direct report (span of control: 10 staff – 1 direct, 9 indirect)
• None

Interacts/Interfaces With: Direct: Indirect:

• Management for reporting and follow through on action points
• Business Heads & Line Management on compliance risk management
• Internal Audit for reports and closure of thereof
• Bank Staff for Compliance Risk Awareness & Training
• Regulators
• Statutory Bodies
• External lawyers
• Funding partners
• Uganda Bankers’ Association
• Government agencies and law enforcement agencies

Job Purpose: The Senior Compliance Manager – AML & Sanctions Risk Management is responsible for overseeing the Bank’s Anti-Money Laundering, Countering the Financing of Terrorism (CFT), and Sanctions Compliance Program. The role ensures effective identification, monitoring, and mitigation of money laundering and sanctions risks in line with national legislation, regulatory expectations, and international best practices. The position also leads investigations, reporting, and training related to AML/CFT and sanctions compliance, and acts as the designated AML/CFT advisor to senior management.

Responsibilities/Key Deliverables:

• To effectively advise, guide the business lines on matters of Anti-Money Laundering & Counter Financing of Terrorism, Proliferation Financing, Sanctions and Anti-Bribery and Corruption.
• Ultimately responsible for ensuring the embedment and enforcement of an adequate and effective AML Program in the Bank.
• To manage the AML Surveillance team, focusing on escalated and high profile cases/alerts, to allow the bank to meet its reporting obligations, legislative and regulatory requirements and to mitigate AML / CFT risks. This is essential to ensure that the entire Bank is conducting business in a compliant manner to avoid operational losses, fines, penalties or reputational damage.
• Develop and review the bank’s Anti-Money Laundering program and strategy ensuring that there are adequately documented policies and procedures in place that include all relevant legal and regulatory requirements.
• Stay abreast of money laundering and terrorist financing trends and typologies and utilize this information during high profile investigations as well as create awareness around new potential risks or AML trends.
• Provide specialist knowledge and leadership to the team, to enable the development, maintenance and implementation of the relevant part of the Functional Framework and provide assurance that business is undertaken in a compliant manner to avoid operational losses, fines, penalties or reputational damage.
• Provide specialist knowledge and leadership of the team ensuring the potential risks arising from the constantly changing legal and regulatory landscape are addressed by benchmarking the framework against international best practice.
• Plan and execute periodic reviews of processes and reporting procedures, inclusive of automated / system enabled processes, identify gaps, risks and potential inefficiencies and lead the development and implementation of new or improved processes and / or system improvements.
• Coordinate and oversee the periodic and ad-hoc systems, processes or data related reviews (e.g. rule tuning, systems verification, transaction monitoring, bank data testing, quality assurance reviews) as per policy, monitoring plan and best practice.
• Oversee the preparation of client risk briefing notes based on identified risks emanating from investigations and brief Executives as required.
• Develop mechanisms and practices to identify and track matters of interest in the media to proactively determine customer risk and advise the business accordingly.
• Collaborate with the Financial Intelligence Authority, as and when required, to address large scale or sensitive financial crimes, as they relate to specific requests issued by the FIA. Participate in joint initiatives / investigations with other teams in the bank.
• Manage in-depth investigations into escalated, high profile, high risk and sensitive in nature, money laundering and terrorist financing activities, Politically Exposed Persons (PEPs), Politically Influential Persons (PIPs) or Tip-Offs.
• Oversee the team of AML analysts with respect to enhanced analysis, research and transaction monitoring to identify and analyze suspicious activities.
• Manage the monitoring of high risk individuals and accounts and ensure that the key stakeholders are kept informed of developments and risks.
• Identify and escalate matters proactively for the attention of line management, and the Country MLCO to bring identified risks to their attention with well formulated and summarized information.
• Personally handle sensitive investigations, freezing orders, regulatory requests or monitoring orders directly, when required to do so.
• AML/CFT Framework Management
• Develop, implement, and maintain a risk-based AML/CFT compliance program in accordance with the Anti-Money Laundering Act BoU regulations, and FIA directives.
• Oversee the Bank’s Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Know Your Customer (KYC) standards.
• Lead the development and periodic review of AML/CFT and sanctions compliance policies and procedures.
• Sanctions Compliance and Screening
• Manage the end-to-end sanctions compliance process including screening of customers, counterparties, and transactions against global sanctions lists (e.g., UN, OFAC, EU, OFSI etc).
• Provide advisory support on cross-border transactions, correspondent banking relationships, and high-risk client engagements.
• Ensure escalation and resolution of potential sanctions breaches or red flags.
• Monitoring, Investigation, and Reporting
• Supervise transaction monitoring processes and systems to detect suspicious or unusual activity.
• Oversee internal investigations into suspicious transactions and activities, including root cause analysis and risk mitigation.
• Prepare and submit Suspicious Transaction Reports (STRs) to the Financial Intelligence Authority (FIA) within statutory timelines.
• Maintain an audit trail and secure case management files for all AML/sanctions matters.
• Regulatory Affairs & Engagement
• Act as the Bank’s key contact for AML/CFT and sanctions-related queries from the Financial Intelligence Authority, Bank of Uganda, or other regulators.
• Lead preparation and coordination for AML/CFT regulatory inspections, thematic reviews, and external audits.
• Track regulatory changes and global developments in financial crime risk management and adjust internal controls accordingly.
• Training and Awareness
• Develop and implement AML/CFT and sanctions compliance training programs for staff, management, and the Board.
• Provide targeted and role-specific training for high-risk business units (e.g., trade finance, remittances, corporate banking).
• Promote a culture of compliance and zero tolerance for financial crime throughout the organization.
• Governance and Reporting
• Provide AML/sanctions compliance reports, dashboards, and incident summaries to the Chief Compliance Officer, Executive Management, and the Board Risk Committee.
• Conduct the enterprise-wide compliance risk assessment to provide assurance of the Financial Crime Compliance posture of the bank.

Financial Responsibility

Job holder is charged with ensuring zero tolerance to penalties due to non-compliance.

Person Specification

Education & Training: Qualification

• LLB or a business degree.
• Certification in regulatory compliance or ACCA or CPA is an added advantage.

Skills & Experience:

• Minimum of 4 years’ experience in financial services and or working in a fast-paced and dynamic regulated environment preferably within the financial crime management experience (KYC/AML/CDD, and other relevant financial crime-related topics).
• A Master’s degree or certification in Audit, Compliance, Business or Law will be an added advantage.
• Exposure to demanding operational environments to gain insight into the most effective compliance management applications
• Working across all levels of the organization to understand cross-functional linkages and interdependencies, as well as the implications of compliance at both a strategic level and at the business unit level.
• Experience of leading and coordinating a team.
• Excellent communication and interpersonal skills, including the capacity to articulate the case for compliance management in the language of business.
• Demonstrated ability to assess Compliance trends, both internally and externally.
• Leadership and management ability.

Business Behaviors:

• Confidentiality and sound business judgment
• Objective thinking
• Ability to exercise discretion when performing duties assigned

• To effectively advise, guide the business lines on matters of Anti-Money Laundering & Counter Financing of Terrorism, Proliferation Financing, Sanctions and Anti-Bribery and Corruption.
• Ultimately responsible for ensuring the embedment and enforcement of an adequate and effective AML Program in the Bank.
• To manage the AML Surveillance team, focusing on escalated and high profile cases/alerts, to allow the bank to meet its reporting obligations, legislative and regulatory requirements and to mitigate AML / CFT risks. This is essential to ensure that the entire Bank is conducting business in a compliant manner to avoid operational losses, fines, penalties or reputational damage.
• Develop and review the bank’s Anti-Money Laundering program and strategy ensuring that there are adequately documented policies and procedures in place that include all relevant legal and regulatory requirements.
• Stay abreast of money laundering and terrorist financing trends and typologies and utilize this information during high profile investigations as well as create awareness around new potential risks or AML trends.
• Provide specialist knowledge and leadership to the team, to enable the development, maintenance and implementation of the relevant part of the Functional Framework and provide assurance that business is undertaken in a compliant manner to avoid operational losses, fines, penalties or reputational damage.
• Provide specialist knowledge and leadership of the team ensuring the potential risks arising from the constantly changing legal and regulatory landscape are addressed by benchmarking the framework against international best practice.
• Plan and execute periodic reviews of processes and reporting procedures, inclusive of automated / system enabled processes, identify gaps, risks and potential inefficiencies and lead the development and implementation of new or improved processes and / or system improvements.
• Coordinate and oversee the periodic and ad-hoc systems, processes or data related reviews (e.g. rule tuning, systems verification, transaction monitoring, bank data testing, quality assurance reviews) as per policy, monitoring plan and best practice.
• Oversee the preparation of client risk briefing notes based on identified risks emanating from investigations and brief Executives as required.
• Develop mechanisms and practices to identify and track matters of interest in the media to proactively determine customer risk and advise the business accordingly.
• Collaborate with the Financial Intelligence Authority, as and when required, to address large scale or sensitive financial crimes, as they relate to specific requests issued by the FIA. Participate in joint initiatives / investigations with other teams in the bank.
• Manage in-depth investigations into escalated, high profile, high risk and sensitive in nature, money laundering and terrorist financing activities, Politically Exposed Persons (PEPs), Politically Influential Persons (PIPs) or Tip-Offs.
• Oversee the team of AML analysts with respect to enhanced analysis, research and transaction monitoring to identify and analyze suspicious activities.
• Manage the monitoring of high risk individuals and accounts and ensure that the key stakeholders are kept informed of developments and risks.
• Identify and escalate matters proactively for the attention of line management, and the Country MLCO to bring identified risks to their attention with well formulated and summarized information.
• Personally handle sensitive investigations, freezing orders, regulatory requests or monitoring orders directly, when required to do so.
• Develop, implement, and maintain a risk-based AML/CFT compliance program in accordance with the Anti-Money Laundering Act BoU regulations, and FIA directives.
• Oversee the Bank’s Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Know Your Customer (KYC) standards.
• Lead the development and periodic review of AML/CFT and sanctions compliance policies and procedures.
• Manage the end-to-end sanctions compliance process including screening of customers, counterparties, and transactions against global sanctions lists (e.g., UN, OFAC, EU, OFSI etc).
• Provide advisory support on cross-border transactions, correspondent banking relationships, and high-risk client engagements.
• Ensure escalation and resolution of potential sanctions breaches or red flags.
• Supervise transaction monitoring processes and systems to detect suspicious or unusual activity.
• Oversee internal investigations into suspicious transactions and activities, including root cause analysis and risk mitigation.
• Prepare and submit Suspicious Transaction Reports (STRs) to the Financial Intelligence Authority (FIA) within statutory timelines.
• Maintain an audit trail and secure case management files for all AML/sanctions matters.
• Act as the Bank’s key contact for AML/CFT and sanctions-related queries from the Financial Intelligence Authority, Bank of Uganda, or other regulators.
• Lead preparation and coordination for AML/CFT regulatory inspections, thematic reviews, and external audits.
• Track regulatory changes and global developments in financial crime risk management and adjust internal controls accordingly.
• Develop and implement AML/CFT and sanctions compliance training programs for staff, management, and the Board.
• Provide targeted and role-specific training for high-risk business units (e.g., trade finance, remittances, corporate banking).
• Promote a culture of compliance and zero tolerance for financial crime throughout the organization.
• Provide AML/sanctions compliance reports, dashboards, and incident summaries to the Chief Compliance Officer, Executive Management, and the Board Risk Committee.
• Conduct the enterprise-wide compliance risk assessment to provide assurance of the Financial Crime Compliance posture of the bank.

• Minimum of 4 years’ experience in financial services and or working in a fast-paced and dynamic regulated environment preferably within the financial crime management experience (KYC/AML/CDD, and other relevant financial crime-related topics).
• A Master’s degree or certification in Audit, Compliance, Business or Law will be an added advantage.
• Exposure to demanding operational environments to gain insight into the most effective compliance management applications
• Working across all levels of the organization to understand cross-functional linkages and interdependencies, as well as the implications of compliance at both a strategic level and at the business unit level.
• Experience of leading and coordinating a team.
• Excellent communication and interpersonal skills, including the capacity to articulate the case for compliance management in the language of business.
• Demonstrated ability to assess Compliance trends, both internally and externally.
• Leadership and management ability.
• Confidentiality and sound business judgment
• Objective thinking
• Ability to exercise discretion when performing duties assigned

• LLB or a business degree.
• Certification in regulatory compliance or ACCA or CPA is an added advantage.