Position Summary
The Sanctions Team Lead is responsible for overseeing the day-to-day operations of the sanctions screening, alerts review, and investigation’s function relating to correspondent banking, intermediary banking, and cross-border payment activities. The role is primarily designated to cover the night shift (11:00 PM to 7:00 AM). However, selected candidates must be flexible and willing to rotate to the day shift (9:00 AM to 5:00 PM).
The role ensures the effective review and disposition of sanctions alerts generated through the Bank's OFAC filtering systems while maintaining compliance with U.S. sanctions laws, OFAC regulations, and internal sanctions compliance policies and procedures.
The Team Lead provides guidance and oversight to Sanctions Analysts, ensures consistent and well-documented alert disposition decisions, manages escalations involving potential sanctions matches, and serves as a key escalation point for sanctions evasion and circumvention concerns. The individual works closely with the Sanctions Head, Payments Operations, Financial Crime Compliance, and Business Units to maintain a robust sanctions compliance framework and mitigate sanctions-related risks.
Key Responsibilities
Investigations and Escalations
- Serve as the primary escalation point for complex sanctions alerts and potential sanctions matches.
- Conduct enhanced reviews of higher-risk transactions, customers, counterparties, and financial institutions.
- Review investigations involving:
- Specially Designated Nationals (SDNs)
- Blocked persons
- Comprehensive sanctions programs
- Sectoral sanctions
- High-risk jurisdictions
- Sanctioned vessels and maritime activity
- Escalate potential true matches, blocked property matters, or OFAC-reportable matters to the Sanctions Manager.
- Assist with sanctions-related investigations and regulatory reporting requirements.
Sanctions Circumvention and Evasion Monitoring
- Identify and escalate indicators of sanctions evasion and circumvention, including:
- Payment message stripping or alteration
- Nested correspondent banking arrangements
- Use of shell companies
- Front companies
- Complex ownership structures
- Third-country routing strategies
- Unusual payment narratives
- High-risk geographic exposure
- Review emerging sanctions typologies and communicate trends to management and team members.
- Recommend enhancements to controls designed to detect sanctions evasion risks.
Regulatory Compliance and Governance
- Ensure compliance with:
- OFAC regulations
- U.S. economic sanctions programs
- Bank Secrecy Act (BSA) requirements, where applicable
- Internal sanctions policies and procedures
- Maintain awareness of sanctions developments and regulatory changes.
- Assist management in implementing new sanctions requirements and program enhancements.
- Support internal and external audits, regulatory examinations, compliance testing, and issue remediation activities.
Qualifications & Experience
Responsibilities
- Key Responsibilities:
- Support management in achieving compliance objectives
- Stay updated on regulatory requirements and escalate issues
- Review and communicate new regulations
- Ensure branch processes comply with regulations
- Manage regulatory examinations and audits
- Respond to regulatory queries
- Distribute regulatory circulars to staff
- Submit monthly compliance reports
- Maintain AML/CFT compliance
- Implement AML monitoring procedures
- Review suspicious transactions
- Support audits and inspections
- Ensure timely handling of transactional referrals and documentation
- Provide input on system and product development
Qualifications
- Key Responsibilities:
- Support management in achieving compliance objectives
- Stay updated on regulatory requirements and escalate issues
- Review and communicate new regulations
- Ensure branch processes comply with regulations
- Manage regulatory examinations and audits
- Respond to regulatory queries
- Distribute regulatory circulars to staff
- Submit monthly compliance reports
- Maintain AML/CFT compliance
- Implement AML monitoring procedures
- Review suspicious transactions
- Support audits and inspections
- Ensure timely handling of transactional referrals and documentation
- Provide input on system and product development
