Senior Manager Market Conduct Risk
Reports to:
CRO
Division:
Risk Management Division
Section/Unit:
Market Conduct Risk Unit
The 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 Accountabilities
Governance and Oversight
Ensure the bank's conduct risk policy is reviewed regularly by senior management in accordance with regulatory requirements
Define and communicate clear roles and responsibilities to operationalize consumer protection standards and conduct risk frameworks
Conduct oversight of functions owning and embedding code of conduct, conflicts of interest, whistleblowing, ABC in line with consumer protection standards and regulations
Develop, maintain and continuously enhance the bank's Market Conduct Risk Framework, methodology, taxonomy and governance standards
Establish a risk-based conduct supervision methodology covering all business lines, products, customer segments and distribution channels
Ensure conduct risk is appropriately integrated within the bank's Enterprise Risk Management Framework and Risk Appetite Framework
Provide independent oversight and challenge over first line implementation of consumer protection standards throughout the customer lifecycle
Oversee governance relating to vulnerable customers and financial inclusion
Risk Assessment
Review controls established by first-line owners to mitigate misconduct risks in third-party dealings; escalate gaps to senior management
Establish, maintain and regularly review a risk register for misconduct risks across all business units
Perform enterprise-wide conduct risk assessments using a risk-based supervisory methodology
Identify inherent and residual conduct risks across products, services, channels and customer journeys
Conduct thematic reviews based on emerging risks, complaints, regulatory findings, incidents and market developments
Develop and maintain the Conduct Risk Universe and Conduct Risk Register
Recommend enhancements to mitigate identified conduct risks
Consumer Protection Regulations
Independently oversee implementation of Consumer Protection Regulation and Consumer Protection Standards
Challenge effectiveness of customer disclosures, transparency and communications
Oversee product governance arrangements including target market assessments and product suitability
Review fair value / value for money assessments for products
Provide oversight over customer onboarding, servicing, complaints, vulnerable customer treatment and account closures
Challenge the effectiveness of complaint root cause analysis and remediation
Product Governance
Independently challenge new product approval processes to ensure customer risks have been adequately assessed
Review customer outcomes throughout the product lifecycle
Ensure conduct risk assessments are completed before launch of new products or material product changes
Regulatory Engagement
Lead market conduct regulatory engagements with CBUAE
Coordinate responses to regulatory examinations
Track remediation plans arising from supervisory reviews
Monitor implementation of regulatory developments
Talent Management
Assess and enhance existing training programs on conduct risk, ensuring employees understand and comply with conduct standards
Provide input and oversight to ensure conduct risk considerations are incorporated into the HR performance evaluation framework
Market Abuse & Integrity
Oversee reporting and escalation of market abuse incidents per insider trading policies, and challenge the adequacy of remedial actions
Provide oversight and input to insider trading policy and procedures to manage market abuse risks associated with the bank's customers
Conflicts of Interest
Provide oversight and challenge on the bank's conflict of interest policy and controls; review and escalate significant conflicts to senior management
Culture and People
Collaborate with product development and marketing teams to ensure the suitability and appropriateness of products and services for customers
Specialized Risk Areas
Collusion Risk: Oversee risks of collusion between parties aimed at manipulating market conditions
Consumer Mobility Risk: Oversee risks related to consumer ease in switching providers
Cooling Off Risk: Ensure customers are provided with adequate cooling-off periods
Sales, Marketing, Advertising, and Promotional Risk: Oversee risks associated with these activities, ensuring regulatory compliance
Solicitation Risk: Oversee risks associated with solicitation practices
Qualifications & Experience
Bachelor's degree in business, law, education, or a related field
3-5 years of experience in regulatory compliance, controls and governance within the banking industry
Strong knowledge of regulatory compliance; excellent communication skills
Areas of Competency
Excellent verbal and written communication skills
Deep knowledge of compliance standards, particularly those related to conduct risk and consumer protection
Knowledge of how conduct risk intersects with operational risk and ability to implement effective control measures
Strong skills in analysing data related to conduct risk incidents, customer complaints, and market abuse, and developing appropriate mitigation strategies
Experience working across compliance, legal, human resources, and business units to ensure alignment on conduct risk matters
Excellent communication skills to engage with internal stakeholders (senior management, business units) and external bodies (regulators, auditors) on conduct risk issues