Compliance Analyst – High-Risk Accounts, Financial Institutions & Sanctions Oversight at Prime Bank Kenya

Job purpose:

To independently oversee and strengthen the bank's control framework for high-risk customers, financial institution relationships, country risk exposure, sanctions governance, and financial crime monitoring. The role ensures accurate KYC/UBO compliance, robust FI due diligence, effective transaction monitoring, and proactive sanctions and country-risk management, while providing clear guidance to the business and protecting the bank from ML/TF/PF, sanctions, reputational, and correspondent banking risks.

Key responsibilities:

High-Risk Customer Portfolio Oversight


Maintain and review the High-Risk Accounts Portfolio, including PEPs, NGOs, real estate, forex bureaus, money remitters, casinos, cross-border traders, and other elevated-risk sectors.
Ensure KYC, Source of Funds/Wealth, and risk profiles are complete, current, and aligned to customer activity.
Confirm correct system risk markings and flags across core banking and AML systems.
Track overdue reviews, deficiencies, and remediation actions; escalate persistent gaps for restriction or exit consideration.


Beneficial Ownership (UBO) & Complex Structures


Validate UBO structures for high-risk customers and FIs in line with regulatory thresholds and control tests.
Review ownership charts, nominee arrangements, trusts, and layered structures.
Ensure UBO data is accurately captured in systems and refreshed upon ownership changes.
Escalate opaque or high-risk structures for Enhanced Due Diligence (EDD).


Financial Institutions (FI) Due Diligence & Risk Assessment


Conduct and maintain annual FI risk assessments, covering jurisdictional risk, products, customers, channels, AML controls, and sanctions governance.
Perform FI Due Diligence (FIDD) and EDD for correspondent banks, remittance partners, PSPs, fintechs etc.
Maintain complete FI due diligence files and ensure timely refresh.
Support onboarding, renewal, and periodic review of FI relationships.


Country Risk, Sanctions & Watchlist Governance


Maintain and periodically update the Bank's High-Risk Countries List, aligned to:

FATF black/grey lists
Sanctions regimes (OFAC, UN, EU)
CBK and internal risk assessments


Communicate country risk updates promptly to branches, business units, Treasury, and Operations.
Maintain and govern internal Restricted / Blacklists, including:

Sanctioned entities and individuals
Blacklisted customers and counterparties
Persons of Interest (POI) lists
Restricted sectors and corridors


Maintain and update a Crypto Exchange & Virtual Asset Risk List, identifying:

Prohibited or restricted exchanges
High-risk VASP jurisdictions
Approved/monitored crypto-related exposures (if any)


Ensure all lists are accurately configured in screening and transaction monitoring systems.
Track regulatory updates and ensure timely system and policy alignment.


RFI, Correspondence & External Inquiries


Coordinate and review Requests for Information (RFIs) from correspondent banks, regulators, and partners.
Prepare accurate, consistent, and well-supported responses on:

KYC and UBO
AML controls and transaction flows


Sanctions screening and country risk management
Track RFI timelines, escalations, and closure.


Regulatory, Management & Audit Support


Prepare inputs for:

High-risk portfolio reports
FI exposure summaries
Sanctions and country-risk dashboards


Support EWRA updates, inspections, and audits with evidence-based documentation.
Maintain audit trails for sanctions decisions, list updates, and escalations.


Controls, Data Quality & Governance


Ensure accuracy and consistency of:

Customer risk ratings
Country risk classifications


Sanctions and blacklist configurations
Identify control gaps and recommend enhancements to systems, SOPs, and escalation thresholds.


Core Competencies & Behavioural Attributes


Analytical Rigor: Strong quantitative ability.
Attention to Detail: Zero-tolerance environment for errors.
Ethics & Independence: High integrity, unbiased judgment, adherence to AML/CFT obligations, and strong confidentiality discipline.
Problem Solving: Ability to resolve trade breaks, data mismatches, AML alerts, and limit issues efficiently.
Technical Mastery: Strong AML/CFT/CPF mastery.
Communication: Clear, concise, and professional reporting.
Collaboration & Relationship Management: Strong cross-functional engagement.
Learning Agility: Ability to adapt to new systems, regulatory changes, and market dynamics.