The Associate Director, FCC Sanctions, PCA is responsible for the tracking, investigation, composition, and escalation of Possible Circumvention Attempts ("PCA") reports. The incumbent will also assist with the drafting of Voluntary Self Disclosures ("VSD") as needed.
Key Roles and Responsibilities
The Associate Director, FCC Sanctions, PCA is responsible for the tracking, investigation, composition, and escalation of PCA reports. As required, the incumbent will also assist with the drafting of VSDs for submission to OFAC.
* Ensure that key changes (to laws, rules, regulations) are implemented (in region/country), in coordination with group communications. * Support relevant stakeholders to make decisions based on current and possible future policies, practices and trends. * Proactively engages with stakeholders to steer business practices towards exemplary regulatory governance
* Works with stakeholders within FCC and Group Sanctions to support units in achieving the Sanctions agenda.
* Ensures that breaches and PCAs are actioned and tracked in accordance with SCB Sanctions Policy and Procedures.
* Interacts with the business and FCC CBA to provide clear understanding of our sanctions program to ensure that corrective actions undertaken by CB clients sufficiently mitigate sanctions risks.
* Works with the stakeholders to drive the develoment of appropriate strategies.
* Provides guideance on proper application and interpretation of Sanctions-related laws, rules, regulations and policies applicable to the SCBA.
* Evaluates changes to policies and procedures to ensure they are consistent with Sanctions requirements and group policies and procedures while refelcting standards of 'best practice.
* Performs analysis of key monitoring risks and trends identified in breach reporting and partners with developing appropriate mitigation strategies.
* Provides advice on the development of appropriate controls for the mitigation of Sanctions risks with a focus on USD clearing and trade finance business.
* Proactively engages with stakeholders to steer business practices toward exemplary regulatory governance.
* Provides guidance on proper application and interpretation of Sanctions-related laws, rules, regulations and policies applicable to the SCBA.
* Supports Standard Chartered Bank Americas in the practical interpretation of Sanctions, particularly OFAC regulation.
Qualifications and Skills
* Proven knowledge and understanding of OFAC, BSA/AML and USA PATRIOT Act * Proven knowledge of regulatory processes and activities with an understanding of applicable regulatory requirements * Have an understanding of variation in such laws and regulations across various jurisdictions * A developed ability of identify and assess risk * Strong writing skills including experience drafting OFAC related reporting such as OFAC Block and Reject Reports and/or Voluntary Self Disclosures submitted to OFAC * Working knowledge of client database and/or transactional sanctions screening processes * Sound experience, shown by demonstrable achievements in the above areas.
Critical Thinking Skills
* Ability to analyse relevant laws and regulations and correlate regulatory issues to products and business models. * Adept ability to identify and articulate compliance issues * Ability to independently problem solve and demonstrate solution finding skills * Ability to carry out data mining and trend analysis
Communication skills & Stakeholder Management
* Ability to ensure that relevant stakeholder receive pertinent and timely information on developments in compliance or in the business, with the priority on ensuring "no surprises" * Advanced ability to lead discussions around complex problems with relevant stakeholders Escalates with a proper sense of urgency