Global Sanctions Compliance Officer

Provides AML/OFAC compliance support to the most complex areas/products in specialized businesses within HBUS and HSBC Group Affiliates.

The Compliance Officer (Specialized) is responsible for tracking and reporting on new and amended (AML/BSA/OFAC) regulations and assessing their impact, to provide direction and counsel directly to the line of business regarding requirements for compliance.

Assists compliance and/or line management, including business, operations and product managers, in implementing changes to products, services, systems, and operations to ensure and maintain compliance.

Monitors assigned products to ensure full compliance with pertinent rules and regulations.

Escalates issues discovered during ongoing review and assessment of AML/OFAC compliance risk that require escalation to Senior Management for direction on resolution.

Makes determinations on applicability of OFAC sanction program regulatory requirements and AML requirements in respect to real time transactions and relationships.

Develops external contacts among industry peer groups to determine/validate that the Company is following and instrumental in developing industry best practice.

Impact on the Business

• 
  
  Responsible for reviewing and investigating escalated payments and/or transactions which have been identified as containing potential matches against Government Sanction lists: OFAC, United Nations, European Union, and others.
  
  
• 
  
  Assists in assessment of potential breaches or violations of U.S. economic sanctions and trade restrictions.
  
  
• 
  
  Assists with maintenance of, and projects relating to, sanctions lists updates and enhancements.
  
  
• 
  
  Identifies OFAC sanctions risks and provides guidance to HSBC Bank USA, N.A. (HBUS) business lines & HSBC Group Affiliates on outstanding matters/transactions.
  
  
• 
  
  Assists in the development, administration, and implementation of the HBUS OFAC compliance program.
  
  
• 
  
  Maintains awareness of regulatory changes relating to AML/OFAC affecting assigned business(es); ensure appropriate communication and development of appropriate policy/procedure changes to remain compliant.
  
  
• 
  
  Reviews and analyzes compliance monitoring reports and other related source documents for suspicious/unusual patterns of activity, providing appropriate response and follow up on areas requiring attention. When applicable, follow-up with responsible area for explanations and discussions for appropriate action.
  
  
• 
  
  Identifies and reports all significant regulatory compliance breaches or gaps to senior management. Collaborate with senior management and relevant internal parties to ensure development and implementation of solutions to prevent future occurrence.

Customers / Stakeholders

• 
  
  Assists management in identifying and containing compliance risk, compliance monitoring and fostering a compliance culture. Works with management in the development and enhancement of products to ensure compliance with applicable laws and regulations; coordinates development and maintenance of supporting policies, procedures, agreements and contracts.
  
  
• 
  
  Provides written summaries to senior management regarding findings in audits/investigations. As appropriate, leads or assists in implementing corrective actions for first, second, third line of defense and regulatory issues.
  
  
• 
  
  Provides assigned data quests/reports to pertinent external regulatory agencies as requested and or assigned, or on a repeating basis

Leadership & Teamwork

• 
  
  Leads and develops an effective team through communication, performance management, development plans and reward/recognition practices.
  
  
• 
  
  Promotes an environment that supports diversity and reflects the HSBC brand.
  
  
  
  
  
  
• 
  
  Complete other responsibilities, as assigned.

Operational Effectiveness & Control

• 
  
  Provides support to assigned areas on compliance-related issues, including documentation and forms review for compliance with applicable regulations.
  
  
• 
  
  Adheres strictly to compliance and operational risk controls in accordance with Company and regulatory standards, policies and practices; reports control weaknesses, compliance breaches and operational loss events.
  
  
• 
  
  Discharges Compliance Officer accountabilities by pro-actively assisting management in identifying and containing compliance risk, monitoring, reporting and certification, fostering a compliance culture and optimizing relations with regulators.
  
  
• 
  
  To implement the Group compliance policy locally by containing compliance risk in liaison with the Head of Group Compliance, Global Business Compliance Officer, Area Compliance Officer or Local Compliance Officer, ensuring adequate compliance resources and training, fostering a compliance culture and optimizing relations with regulators.
  
  
• 
  
  Complete other responsibilities, as assigned.

Major Challenges

• 
  
  The position addresses legal compliance matters in daily activities to ensure regulatory requirements and operating practices within the most complex areas. However, ultimate authority for compliance risk management and policy decisions rest with senior management.
  
  
• 
  
  Positions designated as “specialized compliance” are typically focused on multiple major lines of specialized businesses within a financial institution (i.e. GBM, wealth management, private banking, anti-money laundering (AML), brokerage, etc.). Many of the businesses entail the highest degree of regulatory compliance and reputational risk, particularly with respect to risks arising out of non-compliance with extensive and complex regulations. Failure to comply with these regulations would have significant negative effects on relations with regulators, the reputation of the Company with the public and may result in regulatory impediments to mergers and acquisitions and significant regulatory sanctions, including regulatory fines of material amounts.
  
  
• 
  
  Historical compliance issues in AML place more pressure on this and related functions. The candidate will need to operate effectively under the pressure of deadlines, constant regulatory oversight, and pressure on the level of unit performance

Role Context

• 
  
  Liaises with OFAC on escalated transactions, as needed;
  
  
• 
  
  Demonstrates knowledge of OFAC interdiction filter software technologies;
  
  
• 
  
  Demonstrates knowledge of anti-money laundering (AML) laws and regulations, including USA Patriot Act, suspicious activity reporting and politically exposed persons;
  
  
• 
  
  Has familiarity with international payment practices and systems is preferred (ex. Global Payment Systems (GPS), Society for Worldwide Interbank Financial Telecommunications (SWIFT), Federal Reserve Bank settlements (Fedwire), Clearing House Interbank Payment Systems (CHIPS), Automated Clearing House settlements, foreign exchange transactions, book transfers, etc.);
  
  
• 
  
  Demonstrates thorough knowledge of commercial banking products, services, operations and systems, and extensive dealing with laws, regulations and regulatory agencies related to OFAC sanctions
  
  
• 
  
  Routinely interacts with management for assigned businesses, division and country managers, other Group managers, regional and local compliance functions, and peers throughout the organization and examination officials conducting regulatory examinations. Position also interacts with OFAC.

Management of Risk

• 
  
  Ensure compliance, operational risk controls in accordance with HSBC or regulatory standards and policies; and optimize relations with regulators by addressing any issues.
  
  
• 
  
  Meets all deliverables for QA reviews, analyses, and regular reporting.
  
  
• 
  
  Significant travel may be required.
  
  
• 
  
  Adheres to HNAH’s Statement of Business Principles and Code of Ethics.

Observation of Internal Controls

• 
  
  Maintains HSBC internal control standards, including timely implementation of internal and external audit points together with any issues raised by external regulators.
  
  
• 
  
  Communicates control weaknesses to other group leaders and business management in accordance with issue escalation procedures.