BNY Mellon Careers

EMEA Head of Economic Sanctions

Edinburgh, United Kingdom

Job Description

The role of the EMEA Head of Economic Sanctions is primarily to assist the EMEA Group MLRO and the Head of Global Sanctions in the development and maintenance of a robust sanctions framework for the EMEA Region ensuring compliance with all applicable sanctions programs.  The role includes leading core elements of the framework for EMEA, including:  timely regulatory analysis, rule and controls mapping, supporting policy development and maintenance, training & awareness, in order to support BNY Mellon Lines of Business and Legal Entities in complying with regulatory requirements and expectations and with corporate compliance policies.

Key Responsibilities

• Responsible for oversight of the EMEA sanctions / screening compliance program as stipulated by the Global Economic Sanctions Policy and Global Anti-Money Laundering Policy.
• Act as the Regional Compliance Officer in relation to the requirements within the Global Economic Sanctions Policy, including knowledge of relevant business/business partners and their clients, products/services, vendors, employees, other static data and transactions.
• OFAC / Economic Sanctions Compliance Program: Ensure that each business/business partner has implemented an appropriate OFAC/Economic Sanctions Compliance Program and assist with enhancement and developments as necessary.
• Sanctions Advisory: Provide subject matter expertise on UK and EU economic sanctions laws, regulations and requirements in the UK and EMEA to regional business and business partners as required. In conjunction with the Legal Department and Global Head of Sanctions, evaluate new products and services prior to implementation to identify and respond to regulatory compliance concerns. Serve as escalation point for sanctions issues within EMEA.
• Policies and Procedures: Develop and maintain relevant policies and procedures, including appropriate controls in conjunction with Business Sanction Coordinators and MLROs. Provide input to global policy updates.
• Regulatory Analysis: Respond rapidly to new sanctions developments; Take the lead on analysis of new and amended sanctions related regulations impacting the UK and EU and their applicability in the wider EMEA region.  Working with global, regional and local colleagues, take a leading role on gap analyses, as required, to consider the impact on individual business lines and legal entities, including advising on screening requirements for clients and transactions against EU and local sanctions lists in the UK, EU and EMEA region.  Ensure appropriate support for regulatory projects within impacted areas.
• Identify and respond to potential conflicts of law or regulatory expectation among relevant jurisdictions through consultation with Global Head of Sanctions and Legal Department as necessary.

• Economic Sanctions Awareness & Training: Conduct periodic training needs analysis and design and deliver targeted economic sanctions training in light of that analysis to increase awareness of economic sanctions obligations and internal compliance responsibilities, helping to promote a culture of compliance and control.
• In conjunction with Global Head of Sanctions, assist Business Operations and Technology with the implementation of electronic filter/screening solutions or other appropriate monitoring processes and enhancements thereto applicable in the EU, the UK and wider region.
• Coordinate the regional preparation of the annual blocked property report.
• Assist with the development of the periodic sanctions risk assessments and review and comment on EMEA business and legal entity submissions.
• Review OFAC surveys and Data Lineage Card Submissions prepared by the businesses and coordinate their presentation to the OFAC Advisory Group.
• Act as EMEA representative on OFAC Advisory Group.
• Governance and MI, Escalation and Reporting: In conjunction with MLRO ensure regular economic sanctions updates are provided to the regional Anti-Money Laundering oversight Committee (EAMLOC) and the OFAC Advisory Group, including escalation of significant issues and also development of MI.  

Additional Responsibilities
• Liaising with colleagues/peers in other jurisdictions on Regional Economic Sanctions programme matters and issues of common interest
• Using extensive industry experience to make well informed decisions that have positive impact on the strategic direction of the function and by providing technical advice to the team.


Governance Responsibilities
• Helping to ensure that a strong governance culture is embedded within the region, that issues are escalated and cascaded appropriately and that key risks are identified, discussed and mitigated.
• Building a good understanding of the EMEA governance framework, including escalation requirements.

Generic Staff Responsibilities:
- Comply with all BNY Mellon corporate policies and procedures, including HR policies and procedures and departmental procedures
- Alert management immediately of any significant changes to business risks and internal control effectiveness
- Notify management and the Head of EMEA Compliance and/or the Chief Compliance and Ethics Officer immediately on discovery of any material regulatory breach
- Comply with all Security and Health & Safety policies and procedures operating within the business.


Person Specification:
Core Competencies:
- Adaptability
- Communication
- Customer Orientation
- Interpersonal Skills
- Judgment
- Managing Risk.
Job Specific Competencies / Technical skills / knowledge
- Extensive Economic Sanctions / Compliance / Legal experience
- Thorough knowledge of laws, regulations and expectations of European and UK Regulators
- Working knowledge of US sanctions; knowledge  of other foreign sanctions laws and regulations an advantage
- Ability to work under time pressure in calm, professional manner in an environment of change
- Strong analytical skills, problem-solving ability and attention to detail
- Excellent communication and interpersonal skills
- The ability to handle stressful situations with internal clients and regulators, while maintaining a professional approach to problem solving. 
- Ability to effectively deal with senior management as well as Regulators as required
- Strong planning skills
- Collaborative approach and ability to work well within a team environment
- Proven sound judgment
- Ability to take on and complete tasks with minimal oversight
- Ability to drive compliance requirements in the business and achieve results
- Experience of working in a global firm an advantage
- Experience of working with regulatory bodies an advantage
- Proven leadership abilities with experience of reporting to senior management and governance fora.

Academic/Professional Qualifications (or equivalent qualifiers)
Legal or Bachelor’s degree; experience in sanctions and related fields is required.

BNY Mellon is an Equal Employment Opportunity Employer.

Primary Location: United Kingdom-Lothian Region-Edinburgh
Job: Compliance
Internal Jobcode: 85163
Organization: Compliance & Ethics-HR06015
Requisition Number: 1905391