Independent Director — Bank Financial Crime Governance

Control effectiveness rather than policy completion

This board appointment requires sufficient banking and control expertise to challenge management, while recognising the distinction between oversight and operational case decisions. The director will not undertake investigations or replace the accountable compliance leadership.

Risk, growth and capacity

Assess how the bank understands risk across customers, products, channels and counterparties. Challenge the consistency between that assessment and the resources allocated to onboarding, monitoring, review and escalation. Ask whether growth or change initiatives introduce exposures that existing controls cannot manage reliably.

Data, backlogs and evidence of resolution

Examine the quality of data feeding screening and monitoring processes, the governance of model or rule changes and the treatment of backlogs. Require clear explanation of control limitations and temporary measures. Review assurance findings and ensure repeated weaknesses are addressed at their cause rather than closed through narrow procedural fixes.

The director should question whether performance measures encourage premature closure of cases or conceal the significance of unresolved work. Board reporting needs to show risk, capacity and outcomes in a way that supports decisions about investment and risk acceptance.

Professional depth and independent challenge

Applicants should have senior banking, compliance, risk or audit experience with substantial exposure to financial crime governance. They must understand the practical operation of controls and the consequences of fragmented systems or unclear ownership. Experience overseeing remediation is valuable, especially where it involved difficult choices about growth, customer relationships or resources.

Candidates need independence, discretion and the ability to challenge both technical explanations and commercial pressure. Familiarity with applicable requirements must be demonstrated for the specific appointment; no single prior market experience should be treated as universally transferable.

The director will support collective decisions, follow material deficiencies and ensure assurance has appropriate access and standing. Eligibility, conflicts and any required appointment approvals will be assessed. Management retains responsibility for controls and cases. Success is a board with an honest understanding of residual exposure and credible evidence that weaknesses are being resolved, rather than reliance on volume statistics or declarations that a programme has been completed.