Associate Manager - Anti-Bribery & Corruption

The role is responsible for supporting the organization’s efforts to develop, implement, and monitor a robust Anti-Bribery & Corruption (ABC) program. This role includes assisting in the ABC risk assessment process, managing the whistle-blowing mechanism, and ensuring accurate financial crimes reporting. The Officer will work closely with cross-functional teams to ensure the organization complies with relevant anti-bribery, anti-corruption, and financial crimes regulations. The individual will play a key role in identifying, mitigating, and managing risks related to bribery, corruption, and financial crimes, fostering a culture of integrity across the organization.

Anti-Bribery & Corruption (ABC) 

• Assist in Conducting ABC-related investigations under the supervision of the Head of ABC, including evidence collection, documentary review, system log and transaction analysis, and background checks. 
• Receive, log, and triage allegations of bribery, corruption, internal fraud, and conflicts of interest, and escalate matters meeting defined criteria to the Head of ABC within the required timeframes. 
• Support investigation interviews through preparation of question sets, note-taking, and drafting interview records for review and sign-off. 
• Preserve the integrity of evidence, including chain of custody, access restrictions, and confidentiality of case information. 
• Draft investigation reports setting out background, methodology, findings, root cause, and recommended corrective actions, for review and approval by the Head of ABC. 
• Track agreed remediation and disciplinary actions arising from investigations through to closure and escalate overdue items.

Whistleblowing Cases

• Handle Internal Fraud cases received through the whistleblowing channels under supervision, including initial case assessment, classification, and preparation of an escalation recommendation for management decision. 
• Maintain strict confidentiality and reporter anonymity throughout the case lifecycle, including restricted access to case files, controlled distribution of case information, and adherence to the non-retaliation requirements of the whistleblowing policy. 
• Ensure whistleblowing cases are documented, tracked, and closed in accordance with the applicable policy and regulatory requirements, and monitor case aging against defined turnaround times.

Escalation & Reporting

• Escalate Internal Fraud cases defined significance, materiality, or sensitivity criteria to the Head of ABC promptly upon identification, together with a preliminary case summary.
• Prepare draft escalation memoranda, committee papers, and regulatory notification templates relating to significant Internal Fraud cases, for review, approval, and submission by the Head of ABC.
• Identify and document emerging Internal Fraud typologies, recurring red flags, and material control weaknesses observed across cases, and reflect them in periodic management information and reporting.

Training & Awareness (ABC, Internal Fraud & Whistleblowing)

• Assist in preparing and delivering training and awareness materials on ABC, Internal Fraud, and whistleblowing for employees, management, and relevant third parties, covering applicable requirements, risks and typologies, prevention and detection controls, red flag indicators, and reporting and escalation obligations with content reviewed and approved by the Head of ABC prior to delivery.
• Support delivering induction and periodic refresher training sessions and coordinate the delivery of role-specific training for higher-risk functions, including procurement, third-party management, business development, and staff involved in gifts, hospitality, and sponsorship decisions.
• Coordinate with Human Resources, Learning & Development, and Corporate Communications on the scheduling, deployment, and rollout of training campaigns and awareness materials across available channels.
• Support the development of ABC and Internal Fraud awareness initiatives that promote a strong fraud risk culture, ethical conduct, and employee vigilance, including awareness campaigns, internal communications, and periodic reminders on reporting channels.
• Prepare awareness materials on the whistleblowing channels, covering how to report, the confidentiality and anonymity safeguards in place, and the protection from retaliation afforded to reporters.
• Monitor training completion rates and outstanding assignments, follow up with business units on non-completion, and escalate persistent non-completion to the Head of ABC.
• Maintain complete and auditable training records, including attendance, completion evidence, materials, and version history, to support internal audit and regulatory examination requirements.
• Assess the effectiveness of training and awareness activities through completion data, knowledge assessments, and feedback, and update materials to reflect regulatory developments, findings from investigations, and emerging typologies identified within the Bank.

Financial Crime, Cyber & Counter-Fraud Alignment

• Participate in coordination forums and working groups between Internal Fraud, AML, Compliance, Information Security, Cyber Crime, and Counter-Fraud functions, and contribute to a joined-up approach to identifying, preventing, detecting, and investigating financial crime risks.
• Coordinate with relevant internal functions on cases presenting cross-functional exposure, including cyber-enabled internal fraud, misuse of system access and privileges, and cases with potential money laundering indicators, and refer matters to the relevant function where the case falls within their mandate.
• Support information sharing between control functions on cases, red flags, and typologies within the limits of applicable confidentiality, data protection, and need-to-know requirements, and escalate to the Head of ABC where the scope or ownership of a case is unclear.
• Identify and document linkages and recurring patterns across Internal Fraud, cyber, and other financial crime cases, and reflect these in typology notes and periodic management reporting.
• Perform any other duties assigned to by line manager related to the nature of the work
• Enforce, incorporate, and comply with all necessary controls and related information security policies, procedures, practices, training, reporting, personal due diligence and vigilance, within departmental/unit activities and operations.

Preferred Qualifications

• Have a tertiary level qualification from a recognized institution in Law, Business, Finance, or a related field. 

Years & Nature of Experience

• Recommended 1 to 3 years of equivalent experience where required competencies and experience has been demonstrated
• If with experience would have been accountable a Demonstrated expertise in conducting risk assessments, managing investigations, and delivering training related to ABC, financial crimes, and whistle-blowing programs.
• Familiarity with financial crimes regulations, including anti-money laundering (AML), fraud prevention, and sanctions compliance.

Technical Competencies

• Risk Assessment & Due Diligence
• Investigation & Case Management
• Data analytics

Behavioral Competencies

• Decision Making
• Communication
• Team Work
• Problem solving