This is a replacement of a mission critical role in the OFAC Compliance & Enterprise Risk team. The lead of OFAC Compliance & Enterprise Risk will serve as the company’s liaison to the U.S. Treasury’s Office of Foreign Assets Control (OFAC), the firm’s primary global sanctions regulator.
The role is critical as it supports the bank’s “single window” with the United States Government. Because sanctions constitutes one of the highest risk areas of compliance (over $18 billion in penalties in the last 10 years) and the firm is viewed by regulators as one of the highest risk institutions in the market (due to their global footprint), this position is uniquely critical to the franchise. Failure to carry out any of this unit’s core regulatory obligations could expose the franchise to significant enforcement and reputational risk.
The incumbent will also oversee the Enterprise-Wide OFAC/Sanctions Risk Assessment (EWORA) as mandated by the OCC through a 2010 Consent Order. The OCC reviews the EWORA’s Methodology and Results annually as part of their OFAC Compliance Exam.
Additionally Internal Audit reviews the EWORA annually as part of a separate review of the broader Global Sanctions Compliance Program Audit. Failure to have proper resources and to successfully execute the EWORA will risk possible repeat regulatory criticism, including repeat MRAs and/or inability to complete the BSA/AML Consent Order section on OFAC risk assessment.
The incumbent is also responsible for the Sanctions Intelligence & Investigations role, which carries out investigations in response to administrative subpoenas, conducts historical transaction reviews, and drafts Voluntary Self Disclosures, as well as researching possible sanctions targets, suspect companies, and negative news. The incumbent coordinates efforts with GIU as subject matter expert, and providing feedback to the Chief Sanctions Officer on sanctions targets, risks and industry developments, as well as facilitating cooperation with the US government in sanctions matters. The incumbent also serves as a member of the executive management committee reporting to the Chief Sanctions Officer.
The Head of the company’s OFAC Regulatory Compliance function is a direct report to the Chief Sanctions Officer, and a member of its Executive Management Team. The role is critical to the overall success of the Sanctions Compliance Risk Management practice, must be proactive, and understand how to assess and mitigate OFAC risk; it also requires management experience, excellent communications skills, and sound risk management judgment, as it often involves interaction with key stakeholders within the Company’s senior business management, Compliance, Audit, and applicable regulators.
The incumbent will serve as the firms senior liaison to the U.S. Treasury’s Office of Foreign Assets Control (OFAC) and a single window to the U.S. Government on Sanctions matters (e.g., OFAC Licenses, Subpoenas, Voluntary Disclosures and investigations); it requires to be up to date with regulatory developments/expectations and industry trends, enabling solutions to adjust the program in response to changes in the environment. The incumbent will also enable compliance with applicable laws and the companies Global Sanctions Policy by providing advice on complex OFAC matters, formulating the strategy and managing a team of over 30 Subject Matter Experts in all regions in which the company operates.
General responsibilities include:
- Supervises and maintains the communication with the U.S. Treasury Department’s Office of Foreign Asset Control (OFAC)
- Manages and sets direction for the implementation of processes, standards and procedures for their function and area of coverage within Global Sanctions Compliance (GSC);
- Maintains strong regulatory knowledge of subject matter, products and services, and business processes relevant to their function and area of coverage;
- Understands the Firm’s business and identifies opportunities for improvements and for Compliance to make positive contributions;
- Participates in the development of strategic goals for their function and develops and executes accordingly;
- Consistently improves/develops processes and procedures with a commitment to risk mitigation and responsible finance;
- Key driver in personnel-related matters;
- Liaises with other areas of Compliance support functions and business areas;
Specific responsibilities include:
- Develop and maintain working knowledge of business products/services, the operational process flows, and corresponding sanctions risks and controls;
- Provide advice to lines of business and regions on OFAC sanctions regulations, in coordination with legal, including disposition of escalation of OFAC matches globally and across multiple product lines ranging across a wide gamut of banking activities.
- Work closely with Regional Sanctions Compliance Teams, AML Compliance Risk Management, and Sanctions Legal to evaluate sanctions risks and controls;
- Lead frequent engagement with the U.S. Treasury Departments’ Office of Foreign Assets Control and the U.S. State Department, requires significant credibility and face to face interaction with government officials to deal with complex transactions, licenses and conflicts of laws situations
- Develop risk appetite positions with regard to sanctions-related regulatory and reputational risk issues
- Develop facts as needed to assess inquiries and/or transactional matters;
- Support the sanctions review and approval of new products and services;
- Manage programs, projects and tasks related to the execution of the firms annual enterprise-wide OFAC risk assessment, including the coordinating with Regional
- Developing and maintaining a sustainable global OFAC Compliance function;
- Managing, review and approving of weekly regulatory block/reject reporting and the Annual Report of Blocked Property prior to submission to OFAC;
- Reviewing, preparing and filing license applications and reviewing and approving issuance of global, enterprise-wide communications (OFAC sanctions list updates, program updates, enforcement actions, and other guidance documents)
- 10+ years of experience in banking compliance, legal or other control-related function in the financial services industry and Bachelor’s Degree required;
- Extensive knowledge and expertise of AML and Sanctions regulations, risks and typologies;
- In depth knowledge of, and contacts in, the US Government, especially the Department of the Treasury
- Ability to represent the firm to senior US government officials in order to advocate for the firm and to uphold its reputation
- Ability to track and analyze key regulatory developments in the sanctions space, including liasing with US government officials on pending legislation and regulation
- Experience reviewing and analyzing complex transactions, conducting investigations, and responding to subpoenas and other inquiries from regulators
- Experience with and previous exposure to banking and AML internal control functions and regulators within the US;
- Excellent business intelligence and data analytics skills;
- An ability to lead and influence people across cultures at a senior level using sound judgment, successful execution of strategies; and with an understanding of how to operate effectively across diverse businesses; and
- Excellent written and verbal communication skills.
Please email resumes to Jack Kelly at Jack@ComplianceSearch.com