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Duties and Responsibilities
1. Assist in managing the Compliance Programs, including staying abreast of changes in the regulatory environment, enhancing the Compliance Programs to address changing needs, and increasing efficiencies as appropriate.
2. Develop and update the AML/OFAC and Corporate Compliance Risk Assessments to evaluate the inherent risks, controls, and residual risks in the Compliance Programs, identify any potential gaps in the Programs, and determine compliance test and policies and procedures coverage.
3. Develop, maintain, and update all relevant policies, procedures, and documents related to the Compliance Programs.
4. Assess the need, and conduct testing of, the Compliance Programs.
5. Lead meetings with senior stakeholders, including internal senior management, internal audit, and regulatory examiners.
6. As needed, act as the Secretary of various Compliance Meetings, including the Compliance Committee of Bank's Board of Directors. The responsibilities of the Secretary include the proceeding of the meeting, selecting topics, preparing the materials and finalizing the minutes.
7. As needed, act as the Chairperson of Working Group in accordance with the Board of Directors’ Policy on Enhanced Review of New and Proposed Legal and Regulatory Requirements, which includes staying up to date on regulatory updates that may be impactful to the Compliance Programs.
8. Develop, enhance, and administer the Bank’s training program to promote compliance with the Bank’s compliance-related policies, procedures and processes.
9. Enhance the Bank employees’ knowledge and understanding of compliance requirements and responsibilities through continuous communication and on the job training.
10. Train RCD staff on key elements of the AML/OFAC and Corporate Compliance Programs, so they can execute the Programs accordingly, with a focus on high quality and accuracy.
11. Able to take initiative, work in a fast-paced environment, and respond to compliance-related internal inquiries, as well as third party inquiries from customers, counterparties, the parent bank, and other group entities.
12. Perform the functions of the AML and the OFAC Responsible Officer, as needed.
Management / Supervision
1. Assist in supervising a team of compliance staff of approximately 8 people, including temporary and dually responsible staff.
Special Work Hours
1. As needed, work on U.S. bank holidays (generally, periods of 9am -10am, 12pm - 1pm and 4pm - 5pm), monitor OFAC hits on SWIFT messages on-or-off site. Christmas Day is included.
2. As needed, attend meetings during Japanese Business Hours (e.g. 6PM-8PM EST; 6AM-8AM EST) with parent bank and other colleagues.
Independence and Line of Communication
1. Be consistent with the requirement that the compliance function is independent from management.
2. Maintain lines of communication to the Compliance Committee of the Board of Directors and senior management relating to ongoing compliance with applicable laws/regulations.
3. Carry out the directions of the Compliance Committee, consistent with the requirement that the Senior Compliance Officer is an independent function with the Bank.
4. Independently report pertinent compliance-related information, including suspicious activity reports (SARs) filed with FinCEN, to the Compliance Committee.
5. Has a direct reporting line to the General Manager of Compliance Department and/or delegated senior managers of the Global Compliance Office of the Parent Bank, independently from and without notification to senior management of the Bank, if there is any doubt about compliance within the Bank, a doubt about the independence of the compliance function, or if detecting any conduct which is or could result in a compliance violation in the Bank.
Knowledge/Skills
- MBA degree in relevant field, JD degree, or its equivalent with at least 7 years of related experience in BSA/AML/OFAC and/or Corporate Compliance (i.e. Federal Regulations A – ZZ).
- At least 7 years of experience working in a regulated financial institution, preferably in global custody.
- Strong knowledge of U.S. banking compliance regulations and requirements, including BSA/AML/OFAC.
- Good knowledge of applicable risk management practices required to create a culture of risk management compliance.
- Five or more years of managerial experience.
- Excellent written and oral communication skills.
- Ability to effectively collaborate, multitask, problem solve, recommend actions, manage time, and manage employees.
- Advanced in Microsoft 365 (Excel (macros preferred), PowerPoint, Word, Outlook, and Access.
- Accountable for multiple large, complex processes and programs that impact the department and the Americas Division.
- Ability to develop staff for current and long-term department needs by providing feedback, guidance, and mentorship.
- Ability to provide high quality work by ensuring accuracy and seeking to continuously improve our processes and platforms by embracing new and better ways of doing things.
- Experience working and liaising with IT teams, leading projects relating to Transaction Monitoring Systems, leading tuning and validation exercises.
- Knowledge of Fircosoft is a plus.