OFAC Compliance Officer – Sanctions Alerts Management Lead
Responsibilities
The Vice President, OFAC Compliance Officer – Alerts Management Lead operates as a team lead within the SGUS Sanctions Investigations team. Under the direction of the Head of Sanctions Investigations, this position manages the Sanctions Alert process and conducts investigations into live and static sanctions alerts. This position reports to the Head of Sanctions Investigations. Support the Head of Sanctions Investigations in all matters related to sanctions investigations (e.g., escalations, reporting, investigations, filtering, etc.). The role shall be responsible for coordinating certain run the bank (“RTB”) and change the bank (“CTB”) functions related to the sanctions alerts management process, including coordinating alerts management schedules, providing support and advice on live and static alerts, execution of control functions surrounding sanctions alerts, reporting on key metrics, and investigation into live and static alerts. The role functions as a team lead, managing day-to-day activities of assigned Sanctions Investigations team members.
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.
- Investigate and review complicated investment deals, trade finance operations, and transactions for the various lines of business.
- Review and approve OFAC licensed transaction cases escalated by sanctions investigators team members.
- Lead CTB projects related to sanctions alerts management, identifying potential areas of development and raising such findings to senior management.
- Review monthly metrics report for head office and senior management.
- Conduct quality assurance controls related to certain sanctions alerts functions.
- 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 Head of Sanctions Investigations 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 and development of sanctions related training for employees and overseas SG affiliates as needed.
- Ensure appropriate escalation of serious sanctions related matters to the Head of Sanctions Investigations, OFAC Officer, and AMLO.
- Review for adherence to AML/OFAC Compliance policies and procedures and assist in maintaining these policies and procedures, establishing controls to test for adherence.
Profile required
DIVISION DESCRIPTION:
The Compliance department acts as Second Line of Defense of the corporate banking, investment banking and broker–dealer activities across Societe Generale’s operations, reporting on the compliance risks and issues to local, regional, and head office management. The staff provide the business lines with guidance on relevant laws, rules, and regulations applicable to their activities and the development of related policies, procedures, training, and controls. The department oversees compliance with external and internal rules that govern our banking and financial activities including Know Your Customer, anti-money laundering, anti-terrorism financing, sanctions & embargoes, client protection, market integrity, anti-bribery & corruption, and data protection. Additionally, it provides trade and communications surveillance, and manages transversal support functions that help the department achieve its goals
Société Générale’s US Financial Crime Compliance (“FCC”) Department is responsible for ensuring compliance with anti-money laundering (“AML”), Bank Secrecy Act, USA PATRIOT Act, OFAC and sanctions regulations for the operations of SG in the U.S. The Department performs, among other responsibilities, AML transaction monitoring and SAR filing, OFAC screening and reporting, as well as advisory and control functions across SGUS bank and broker dealer businesses. The Department is also responsible for the management of the tools used for sanctions screening and AML transaction monitoring. The Sanctions Compliance Americas Department operates under FCC.
The Sanctions Investigations Team serves as OFAC subject matter experts and is responsible for reviewing and investigating all potential violations of OFAC, E.U. and other sanctions programs processed through or otherwise involving SGUS. The Sanctions Investigations team is functionally divided into two workstreams – Alerts Management and Sanctions Remediation.
Alerts Management is primarily responsible for:
- Review and final approval of escalated live transaction and static data alerts. The team serves as the final review level for interdicted live transactions that require review by Sanctions Compliance.
- Review and approval of OFAC licensed transactions.
- Compiling metrics and other key data points to address sanctions risk.
- In conjunction with Sanctions List Management, review and approval of internal list changes / requests as well as local filter rules.
- Oversight and training for earlier transaction review levels and middle and back-office functions who support SG’s Sanctions Compliance program.
- Execution of key change initiatives related to sanctions alert management and processes.
SKILLS AND QUALIFICATIONS:
Must Have:
- A bachelors degree, preferably Political Science, Finance or Business, Public Administration, International Relations.
- Significant relevant work experience related to OFAC Sanctions Compliance (at least 10 years) may substitute for educational requirements.
- At least six years of work experience in a compliance or regulatory affairs capacity, with at least four years focused on OFAC sanctions compliance. This experience can be gained from either the private or public sector, or any combination thereof.
- At least three years work experience as an OFAC subject matter expert decisioning live transactions escalated for sanctions compliance
- Strong knowledge of OFAC and EU sanctions regulations and USA PATRIOT Act.
- Ability to multitask and manage multiple deliverables and a range of OFAC risk management responsibilities.
- Strong interpersonal, written, and verbal communication skills.
- Excellent research and analytical skills.
- Ability to conduct legal and investigative research utilizing open-source and private research systems.
- Proficiency with word processing, computer applications, databases and spreadsheets including but not limited to: MS Word, Excel, Outlook, and SharePoint.
- High ethical standards, as well as respect for confidentiality and privacy.
Nice to Have:
- Familiarity with FircoSoft and PEGA is a plus.
- A masters degree in a related field or JD is a plus
- Previous experience working at a financial regulator or compliance enforcement agency, such as OFAC, is a plus
Business insight
OUR CULTURE:
At Societe Generale, we live by our 4 core values of commitment, responsibility, team spirit and innovation. We are engaged and demonstrate consideration for others. We act ethically and with courage. We focus our talent and energy on collective success. We experiment and propose new ideas. This way, we maximize our ability to serve client needs and anticipate market changes. Societe Generale is committed to strengthening bonds with colleagues, communities, and the world in which we live, because relationships are at the heart of how we operate.
For more information about our Culture and Conduct initiatives, please visit this link (https://americas.societegenerale.com/en/careers/get-know-culture/)
D&I:
Our Diversity & Inclusion Mission: Recruit, develop, advance, and retain a diverse workforce that is united in our efforts to enhance our competitive position and deliver innovative solutions to our clients.
Our Diversity & Inclusion Vision:
• Engaged workforce that is demographically diverse in a way that reflects the communities in which we operate
• Inclusive culture and workplace that recognizes employees' unique needs and utilizes their diverse talents
• Engage our community and marketplace, and position the organization to meet the needs of all its clients
For more information about our D&I initiatives, please visit this link (https://americas.societegenerale.com/en/societe-generale-about/diversity-and-inclusion/)
HYBRID WORK ENVIRONMENT:
For most positions, Societe Generale offers a hybrid work arrangement that offers employees the flexibility to work remotely, as well as on-site, in order to promote interaction and collaboration with colleagues while adhering to all SG standard protocols. Hybrid work arrangements vary based on business area. The applicable Business lines will determine and communicate the work arrangements that best meet their business needs.
COMPENSATION & SALARY RANGE:
Base salary range does not include overtime pay, bonus and/or other benefits, where applicable. Actual base salary offer will vary based on skills and experience.
Societe Generale is an equal opportunity employer, and we are proud to make diversity a strength for our company. We are committed to recognizing and promoting the talents and achievements of our employees and staff, regardless of race, religion, color, national origin, sex, disability, age, gender, sexual orientation, and any other characteristic or status protected under applicable law.