Andrew Fleming Ica Aml Dip

Manage two teams, Demand Management and Programme Management, delivering financial crime compliance and non-financial crime risk MI, dashboards and regulatory reporting across Deutsche Bank on behalf of their MI and Reporting utility, as part of the change and transformation process to deliver accurate and complete MI.

Global Compliance MI Senior Risk Reporting Manager: I managed a team of six working in HSBCs Global Compliance MI team to deliver financial crime risk metrics for the senior leadership and delivery of the AML Monthly Management Report (AML MMR). I lead on the delivery of financial crime risk projects including the development of Tax Evasion metrics and Intelligence Led Financial Crime Risk Management (ILFCRM) and was responsible for ensuring that HSBC had a QA process for the Financial Crime MI (FCR MI) report Global, Regional and Country level, and that those control processes were demonstrably robust and effective. I was also engaged in developing global cybercrime risk projects to deliver controls to manage cybercrime, data loss (GDPR), and fraud loss through cybercrime attacks as well as looking at ways to use AI (RPA, ML, & DL) to reduce financial crime risk and deliver a better servicer to our customers. These projects required active stakeholder engagement and effective communication.

I managed 145 AML metrics and was responsible for ensuring that effective risk controls were put in place to manage HSBCs AML risk from Business line through to global reporting. I ensured that risk analysis was conducted on the data received and that the relevant commentary breaking down and explaining that risk was delivered in line with the BUs AML 4th Directive risk criteria. This included acting in an advisory function for other teams and departments within HSBC to ensure that they complied with AML policy when designing new products which required AML metric input. I was also responsible for providing responses to the Monitor under the Deferred Prosecution Agreement (DPA), performing oversight on reports and projects, while managing and audit requirements.

I was engaged as a financial crime subject matter expert in a remediation project within Deutsche Bank's AML FIU to access commercial customers transactions for potential AML/sanction issues. This included raising SARs, conducting EDD customer reviews, including negative news screening and making recommendations on exit.

This company provides internal financial risk reduction solutions, focused on money laundering, sanctions and countering financial terrorism, including reviews of their management information, governance and control systems, ID&V and their policies. I have briefed legal teams on client vulnerability, designed effective management information system and control functions and created training programmes to combat financial terrorism, fraud, sanctions, money laundering, bribery and corruption.

Co-op: I was engaged on an assurance project as a financial crime Subject Matter Expert (SME) on AML and sanctions on a review of first line operations and the change programme at the Co-op, identifying and prioritising financial crime risk issues. I interviewed staff across a number of disciplines, reviewing for unusual activity, SARs, overseas payments, customer on-boarding, KYC and CDD and assessed systems and processes to ensure that AML and Sanction risk was managed according to control standards and policy HSBC: I was engaged as an assurance specialist on HSBCs PRO Global Standards quality assurance project. I designed question sets for deep dive visits and conducted gap analysis on critical management processes. I conducted interviews of staff from the Country CEO down to front line staff across their four business lines and FCC to ensure that they were compliant with HSBCs AML and Sanctions policies and that the management information (MI) produced provided traceability back to the policies. This entails conducting artefact reviews and assessing line of business procedures and departmental information manuals across all countries where HSBC operates and accessing processes covering UARs, SARs, CDD and transaction monitoring to ascertain the effectiveness of their MI, the visibility of that MI and its compliance with the AML and Sanction policies in line with Monitor recommendations.

Provided quality assurance and assessment of complaints made to the PHSO and rectified any outstanding issues which had not been resolved by the initial complaint handling team. This included assessing what did happen, identifying what should have happened and the provision of a written report recommending how to resolve the issue if the Health Service was found to be at fault.

In this specialist role I managed 10 teams of detectives charged with the investigation of theft, fraud, money laundering, cyber enabled crime, bribery, corruption, asset seizures and provided MI supported by relevant reports and documentation. Leading on transformational change, I created a unit to investigate high risk financial allegations leading to significantly higher detection rates and more effectively managed reputational risk issues. Through my extensive liaison with key international stakeholders and a presentation to Eurojust in The Hague backed by relevant reports and intelligence breakdowns, I was able to secure funding for a Joint Investigation Team between the UK, Sweden, Finland, Iceland and Cyprus to investigate cross border investment fraud. I also managed a multi-unit cyber fraud investigation across a number of counties, which led to the identification, prosecution, and conviction of an individual targeting victims through use of specialist online marketing companies. As financial crime lead, I conducted investigations into private companies, government agencies and charities, advised on their reporting structures and liaised with industry bodies providing guidance on financial crime compliance, MI systems, policies and procedures to reduce fraud losses and minimise their exposure to risk. Through an in-depth review of intelligence and crime information reports and liaison with industry intelligence specialists, I identified a nationwide organised crime network infiltrating banking call centres. I briefed financial industry leaders, provided guidance to card issuers and wrote detailed reports for senior MPS management on this crime category and identified risk factors for the service and public, which I supported with structured management information reports and detailed intelligence breakdowns. This resulted in the allocation of additional resources and the creation of a New Scotland Yard based unit to specifically target this crime.

I led a team engaged in the investigation of complex financial crime in foreign jurisdictions, including CFT investigations, working in partnership agencies such as the IRS, OFAC, FBI, SO15 and European investigatory bodies. I initiated changes that eliminated our backlog and implemented quality control systems to facilitate clear identification of priority cases whilst ensuring the highest standard of investigative quality and compliance. I also instigated a review of costs which significantly reduced our financial outlays to telecom agencies and provided management information for both the Home Office and senior management. I delivered lectures on cross border financial crime and organised crime networks to foreign judiciary, banks, foreign law enforcement officers including counter terrorism officers at conferences in the UK and Europe. I also briefed the Home Office on current international crime trends including cybercrime, bribery, fraud, terrorist financing, anti-money laundering, sanctions and the implementation of European Framework decisions and UK legislation change.

Like all police officers I began my service as a constable and worked my way steadily through a wide foundation of training and development allowing me to successfully transfer subsequently to detective duties after demonstrating an intelligent and competent eye for detail, enquiry and observation and clear success at professional personal interaction.