Support the Deputy OFAC Officer/Head of Investigations in all matters related to sanctions investigations (e.g., escalations, reporting, investigations, licensing, and disclosures). The person shall be responsible for taking the lead on certain run the bank (“RTB”) and change the bank (“CTB”) functions related to sanctions investigations, including approving licensed transactions, reviewing draft OFAC filings and responses to OFAC requests for information (RFIs)/administrative subpoenas. The position reports to the Deputy OFAC Officer/Head of Investigations.
Responsibilities include, but are not limited to:
- Identify OFAC compliance issues/concerns and make suggestions and/or take corrective action to implement solutions to improve controls/operations.
- Review written products analyzing sanctions investigations, including draft OFAC filings.
- Investigate and review complicated investment deals and transactions for the various lines of business.
- Lead CTB projects related to the remediation of procedural and/or control gaps.
- Review monthly metrics report for head office and senior management.
- Review annual blocked property report as well as foreign regulatory filings.
- Help to facilitate governance over sanctions lists/screening framework
- Assist in the review of OFAC regulatory examination and internal audit deliverables.
- Provide timely advice and guidance to all appropriate business units for OFAC concerns.
- Provide subject matter expertise to the Group Sanctions Compliance office for OFAC and U.S. specific sanctions.
- Provide advice and support to the Deputy OFAC Officer on policies and procedures to ensure compliance with OFAC filtering and reporting requirements for all business units.
- Keep abreast of SG Group sanctions policies, OFAC sanctions, and respective reporting requirements.
- Be a central point of contact for OFAC related escalations, both from junior employees and SGUS business lines/support functions.
- Seek guidance directly from OFAC as necessary.
- Assist in the provision of sanctions related training for employees as needed.
- Ensure appropriate escalation of serious sanctions related matters to the OFAC Officer and AMLO.
- Review for adherence to AML/OFAC Compliance policies and procedures and assist in maintaining these policies and procedures and establishing controls to test for adherence.