Director, Compliance and Control, OFAC/Economic Sanctions Advisory Officer
Location: New York, New York
Type: Full Time
Internal Number: 20444998
BNY Mellon is a global investments company dedicated to helping its clients manage and service their financial assets throughout the investment lifecycle. Whether providing financial services for institutions, corporations or individual investors, BNY Mellon delivers informed investment management and investment services in 35 countries. As of March 31, 2020, BNY Mellon had $41.7 trillion in assets under custody and/or administration, and $2.2 trillion in assets under management. BNY Mellon can act as a single point of contact for clients looking to create, trade, hold, manage, service, distribute or restructure investments. BNY Mellon is the corporate brand of The Bank of New York Mellon Corporation (NYSE: BK). Additional information is available on www.bnymellon.com . Follow us on Twitter @BNYMellon or visit our newsroom at www.bnymellon.com/newsroom for the latest company news.
To provide compliance (second line of defense) advice and challenge to a particular business or line of businesses in relation to OFAC/economic sanctions/financial crimes compliance (FCC), particularly US, EU, and UK, with a focus on other jurisdictions as dictated by business needs.
Role description and responsibilities:
Risk and Compliance provide risk and compliance services across all BNY Mellon businesses including the following groups: Risk Management, Compliance, Global Corporate Security, Information Risk Management and Global Business Continuity. Risk Management oversees and delivers risk services and ensures new business risks are reviewed and approved. Compliance helps ensure BNY Mellon's businesses maintain appropriate processes to comply with applicable laws, regulations.
The role holder will be the economic sanctions advisory lead for BNY Mellon banking businesses (e.g. Global Payments, Cash Management, Trade, Correspondent Banking, Asset Servicing, Depository Receipts, Corporate Trust) which will be the principal focus of the role. Sanctions advisory responsibilities will cover all relevant business activities globally, as required. Key responsibilities include:
Provide advice and guidance to the first line of defence (1LOD) on economic sanctions issues and the application of policy requirements to their business lines and customers, as required;
Review and challenge business line economic sanctions policies, standards, and procedures, at implementation and subsequent review;
Provide review and challenge for 1LOD economic sanctions risk assessments to ensure they are appropriate and completed in compliance with corporate and regulatory requirements to include all relevant risks and controls, and reflect the economic sanctions risks associated with the relevant business line / legal entity;
Review and challenge other financial crimes related control documentation, including in relation to transaction monitoring data lineage and sanctions surveys;
Provide advice to 1LOD in ensuring that economic sanctions risks are assessed in relation to changes to systems, customer onboarding, new products, acquisitions and any other relevant projects;
Support Sanctions Legal and the Global Head of Sanctions with complex license requests, voluntary disclosures, requests for guidance from sanctions authorities, and conflict of law matters;
Provide support to sanctions regulatory requirements impacting the business;
Act as a senior point of escalation for sanctions-related queries, incidents, and potential breaches;
Support the business in enhancing organizational and control structures suitable for facilitating intended transactions in a well-defined compliance environment;
Continuously monitor and proactively develop initiatives to better manage sanctions risk;
Contribute to overall economic sanctions governance and represent Sanctions Compliance on committees, as required;
Work closely with MLROs on multi-jurisdictional economic sanctions issues implicating the relevant business line / legal entity;
Assist with annual MLRO report preparation, as requested;
Work with other economic sanctions/FCC teams where required on global policies and standards, training, and other initiatives of common interest;
Keep up to date with regulatory developments and issues in the economic sanctions/FCC space;
Represent BNY Mellon at relevant external industry forums, as required, to ensure awareness of industry developments and market practice;
Provide support and input on ad hoc issues to other team members, as required;
Provide 1LOD with FCC advice and guidance, including related to particular issues, policies, procedures, and risks that may arise, to include anti-money laundering (AML) and anti-bribery and corruption (ABAC), as necessary and appropriate;
Provide oversight, review, and challenge of financial crimes control processes and procedures implemented within the relevant business / line legal entity, liaising with SMEs in other financial crimes disciplines, as required; and
Assist in development and imparting FCC/sanctions training content and provision of guidance on specialist or high risk training programs.
A successful candidate should ideally have these qualifications:
Subject matter expert (10+ years) experience in Office of Foreign Assets Control regulations, as well as knowledge of non-U.S. sanctions regulations, and FCC specifically related to financial services sector;
Prior experience working within U.S. Financial Institutions with regards to their U.S. Department of the Treasury - Office of Foreign Assets Controls sanctions compliance program;
Significant prior experience in financial crimes compliance within the financial services sector;
Experience working with or at regulatory supervisory bodies;
Experience driving and influencing change in global initiatives;
Proven experience in building and leading teams;
Proven experience interacting with senior management and building constructive partnerships with diverse stakeholders, and challenging where required;
Excellent skills at communicating with various stakeholders across the organization, with strong focus on problem solving;
Excellent skills at driving and promoting the Company's values and ethical framework;
Ability to articulate sensitive, complex or potentially contentious issues in a constructive manner and create appropriate solutions;
Highly committed to both a demanding and changing work environment; and
Advanced degree from an accredited university.
BNY Mellon assesses market data to ensure a competitive compensation package for our employees. The base salary for this position is expected to be between $122,000 and $275,000 per year at the commencement of employment. However, base salary if hired will be determined on an individualized basis, including as to experience and market location, and is only part of the BNYM total compensation package, which, depending on the position, may also include commission earnings, discretionary bonuses, short and long-term incentive packages, and Company-sponsored benefit programs. This position is at-will and the Company reserves the right to modify base salary (as well as any other discretionary payment or compensation) at any time, including for reasons related to individual performance, change in geographic location, Company or individual department/team performance, and market factors.
For over 230 years, the people of BNY Mellon have been at the forefront of finance, expanding the financial markets while supporting investors throughout the investment lifecycle. BNY Mellon can act as a single point of contact for clients looking to create, trade, hold, manage, service, distribute or restructure investments and safeguards nearly one-fifth of the world's financial assets. BNY Mellon remains one of the safest, most trusted and admired companies. Every day our employees make their mark by helping clients better manage and service their financial assets around the world. Whether providing financial services for institutions, corporations or individual investors, clients count on the people of BNY Mellon across time zones and in 35 countries and more than 100 markets. It's the collective ambition, innovative thinking and exceptionally focused client service paired with a commitment to doing what is right that continues to set us apart. Make your mark: bnymellon.com/careers.
BNY Mellon is an Equal Employment Opportunity/Affirmative Action Employer. Minorities/Females/Individuals With Disabilities/Protected Veterans. Our ambition is to build the best global team - one that is representative and inclusive of the diverse talent, clients and communities we work with and serve - and to empower our team to do their best work. We support wellbeing and a balanced life, and offer a range of family-friendly, inclusive employment policies and employee forums.