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Banking/Attorney/In House/West Palm Beach, Florida

Company Name:
BITSOFT INTERNATIONAL, INC.
Director of International AML
The candidate will report directly to the BSA/OFAC Officer. Will lead the Office of Foreign Asset Control (OFAC) Compliance Program, Foreign Corrupt Practices Act (FCPA) anti-corruption programs and other activities related to economic and trade sanctions risk mitigation efforts for domestic and international sanctions while managing international business lines (Elavon, RPS and CPS). Responsible for refining the program's metrics to draw accurate conclusions in an effective manner in order to identify patterns and trends around the risk health of the program. Also responsible for communicating conclusions reached from data interpretation to Senior and Executive Management in an efficient and timely manner. Provide oversight and direction for the daily operations of the International Compliance Program. Serve as subject matter expert and central point of contact for OFAC / FCPA operations and policy. Oversee and approve the publication of OFAC / FCPA procedures and policy. Maintain expert knowledge of OFAC's country sanction programs implemented pursuant to the International Emergency Economic Powers Act (IEEPA), and comprehensive knowledge of OFAC's sanction programs directed against targeted activities such as Narcotics Trafficking, Terrorism, Non-Proliferation of Weapons of Mass Destruction, and Transnational Criminal Organizations. Manage the implementation of OFAC regulations into the operating environments and impacted Business Units. Provide the annual update to the OFAC Program document. Lead the preparation of UB's annual OFAC Risk Assessment. Through continuous efforts, maintain a sustainable, effective and efficient Program designed to meet requirements imposed by OFAC, FCPA and Bank regulators. Provide timely OFAC and FCPA advice and guidance to all affected business units including BTMU head office and affiliates. Process and document the Bank's response to any administrative subpoenas received from OFAC. Research the transactions, analyze the sanctioned activities, and implement corrective actions. Ensure all of the Bank's OFAC screening platforms are effectively scanning account names and transaction details. Ensure screening applications are properly maintained and they are using current OFAC SDN Lists. Ensure screening results are reported, reviewed, correctly decisioned and appropriately documented. Lead investigations and/or due diligence reviews where OFAC issues are present, manage OFAC issues arising from transaction monitoring, Section 314(a/b) Information Sharing or inquiries from government agencies. Manage responses to OFAC-related subpoenas and requests from law enforcement and regulatory agencies. Lead the selection, development and enhancement of OFAC and anti-corruption screening and monitoring automation. Ensure OFAC sanctioned transactions are effectively blocked, rejected, and/or returned to production. Ensure the enterprise observes OFAC reporting requirements for 10-Day Reports and the Annual Report of Blocked Properties. Assure effective procedures and policies are maintained and observed for transactions processed under general or specific OFAC license(s). Oversee the administration and delivery of general and business unit specific OFAC / FCPA training programs. Administer and maintain the operational readiness of Bank's OFAC Affidavit Program. Ensure the timely review and decisioning of new affidavit requests. Ensure Bank's OFAC and Anti-Corruption Program supports current industry best practices and is both efficient and effective. Review Business Unit operating procedures and internal controls to ensure compliance with OFAC filtering and reporting requirements. Reassess OFAC risk controls for business units and product lines at least annually, or as required by circumstances. Monitor patterns and trends in statistical data and lead the implementation of adjustments accordingly. Manages a staff of BSA/OFAC/FCPA professionals and is responsible for all aspects of leadership for the unit; this includes interviewing, hiring, discipline, training, coaching, writing and delivering performance appraisals, compensation changes, promotions and transfers, delegating assignments, oversight of work and termination of employment. Effectively manage budget and other administrative matters as they relate to the International Compliance Program. Establish goals, metrics and reporting systems regarding the performance of the International Compliance Program. Grow and develop a high level of expertise of OFAC and FCPA Operations. Analyze and document potential FCPA violations. Maintain operating procedures and reporting for providing this support. Maintain effective monitoring and reporting processes for corruption and bribery. Ensure an adequate books and records process is maintained. Work with senior management to prepare for and respond to internal audit and regulatory examination reviews. Advise, formulate and implement strategic and tactical corrective measures to address audit and regulatory findings. Work with regulators and US Treasury Department officials to ensure expectations and regulatory requirements are constantly met.

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