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Sanctions Program Execution Risk Manager
3 years ago

Sanctions Program Execution Risk Manager



New York, New York



**Job Description:**



The Global Financial Crimes (GFC) Manager executes substantive money laundering, economic sanctions and fraud compliance and operational risk practices relevant to the manager's specific area of responsibility. The GFC Manager is accountable for the requirements of the Global Compliance and Financial Crimes Enterprise Policies, Compliance and Operational Risk Management Program (CORM Program), the Global Compliance - Enterprise Policy, the Operational Risk Management Enterprise Policy (collectively the Policies) and the Enterprise Fraud Risk Management Standard and works directly or through compliance officers for the Front Line Units (FLUs) and Control Functions (CFs) to complete those requirements.



The GFC Manager proactively engages with other Chief Compliance and Operational Risk (C&OR) officers, including horizontal coverage owners and Enterprise Areas of Coverage (EAC), to provide comprehensive oversight of FLU/CF activities. This role develops and maintains a global coverage plan which defines the scope and risk-based focus of the second lines risk management activities. The GFC Manager prepares materials for C&OR regulatory exams/audits/inquiries and may provide consultation to business leaders in preparation for FLU/CF regulatory exams/audits/inquiries. The GFC Manager also contributes as a manager responsible for providing leadership direction to attract, assess, develop, motivate and retain a team or may act as an individual contributor.



Activities this role performs include, but are not limited to:



Produces and/or oversees independent financial crimes risk management reporting to Global Compliance & Operational Risk (GC&OR) Senior Leaders and FLU/CF Senior Leaders via established governance and management routines

Participates in industry forums and monitors regulatory expectations, emerging legislation and regulation, political scrutiny, litigation and key influencers (trade associations, PACs, lobbyists, consumer groups, and media) in the EAC subject area to identify and mitigate emerging risks

Identifies regulatory training needs and provides subject matter expertise to support the development of training curriculum

Advises and directs the development and maintenance of financial crimes owned policies and standards and the review of relevant FLU/CF-owned policies and standards to ensure that regulatory requirements and operational risks are appropriately addressed

Monitors the changes in regulations applicable to Global Financial Crimes, including advising business leaders on those changes, directing the appropriate areas to implement or amend policies, standards, procedures and/or processes to address regulatory requirements, and challenging the implementation plan as needed; ensures a comprehensive regulatory inventory

Identifies, aggregates, reports, escalates, inspects and challenges the remediation and thematic analysis of FLU/CF-owned issues and control enhancements related to financial crimes

Escalates financial crimes related compliance and operational risks and issues to appropriate governance routines, management/board level committees

Responsible for the remediation of financial crimes related C&OR owned issues and control enhancements to ensure they are addressed appropriately and timely

Participates in the development and maintenance of the global financial crimes coverage plan which defines the scope and risk-based focus of the second lines risk management activities and/or oversees execution of monitoring, testing, and risk assessments, communicate results

Reviews and challenges the FLU/CF process, risk, control (PRC) inventory and FLU/CF Risk & Control Self-Assessment (RCSA)

Reviews and challenges internal and external operational loss events, including development of remediation plans to strengthen controls, and approves where appropriate

Participates in Scenario Analysis activities for coverage areas and challenges as appropriate

Ensures metrics are designed to measure key risks and control performance, monitors and reports on metric performance and breach remediation



Additional activities may include:

Partners in the filing of all regulatory reports for the Company related to Financial Crimes

This role may have Money Laundering Reporting Officer responsibilities



Objective: The sanctions program execution risk manager is responsible for setting the enterprise sanctions risk management strategy, together with the GES Executive, and for overseeing implementation across Front Line Units.



Policies and Standards

Review Financial Crimes Policies and Standards and compare against 2nd line of defense activities to confirm coverage of key requirements

Monitoring & Testing

Provide enterprise overview of all sanctions-related monitoring & testing and perform thematic reviews

Propose and challenge changes related to sanctions monitoring & testing activities to ensure alignment with strategic

Issues

Manage GES owned issues

Provide enterprise overview of all sanctions-related issues and perform thematic reviews

Review new sanctions issues for appropriate theme/sub-theme classification and thematic concerns and recommend issue expansion and/or regrade of severity

Metrics and Reporting

Execute management reporting on key significant matters

Aggregate month end risk metrics and perform thematic reviews

Risk Assessment

Set, together with the GES Executive, the Risk Assessment strategy

Review periodic and targeted Risk Assessments to ensure alignment with the strategy

Participate in risk assessment calibration exercises

Strategy and Process Improvement

Define, together with GES Executive, the enterprise sanctions strategy, and oversee its implementation

Oversee works streams involving sanctions processes



Required Skills: Minimum Years Business & Functional Experience: 7 Years

Degree Required: Bachelors degree or equivalent experience



Desired Skills: Financial Services and/or related government entity



**Job Band:**



H4



**Shift:**



1st shift (United States of America)



**Hours Per Week:**



40



**Weekly Schedule:**



**Referral Bonus Amount:**



0



**Job Description:**



The Global Financial Crimes (GFC) Manager executes substantive money laundering, economic sanctions and fraud compliance and operational risk practices relevant to the manager's specific area of responsibility. The GFC Manager is accountable for the requirements of the Global Compliance and Financial Crimes Enterprise Policies, Compliance and Operational Risk Management Program (CORM Program), the Global Compliance - Enterprise Policy, the Operational Risk Management Enterprise Policy (collectively the Policies) and the Enterprise Fraud Risk Management Standard and works directly or through compliance officers for the Front Line Units (FLUs) and Control Functions (CFs) to complete those requirements.



The GFC Manager proactively engages with other Chief Compliance and Operational Risk (C&OR) officers, including horizontal coverage owners and Enterprise Areas of Coverage (EAC), to provide comprehensive oversight of FLU/CF activities. This role develops and maintains a global coverage plan which defines the scope and risk-based focus of the second lines risk management activities. The GFC Manager prepares materials for C&OR regulatory exams/audits/inquiries and may provide consultation to business leaders in preparation for FLU/CF regulatory exams/audits/inquiries. The GFC Manager also contributes as a manager responsible for providing leadership direction to attract, assess, develop, motivate and retain a team or may act as an individual contributor.



Activities this role performs include, but are not limited to:



Produces and/or oversees independent financial crimes risk management reporting to Global Compliance & Operational Risk (GC&OR) Senior Leaders and FLU/CF Senior Leaders via established governance and management routines

Participates in industry forums and monitors regulatory expectations, emerging legislation and regulation, political scrutiny, litigation and key influencers (trade associations, PACs, lobbyists, consumer groups, and media) in the EAC subject area to identify and mitigate emerging risks

Identifies regulatory training needs and provides subject matter expertise to support the development of training curriculum

Advises and directs the development and maintenance of financial crimes owned policies and standards and the review of relevant FLU/CF-owned policies and standards to ensure that regulatory requirements and operational risks are appropriately addressed

Monitors the changes in regulations applicable to Global Financial Crimes, including advising business leaders on those changes, directing the appropriate areas to implement or amend policies, standards, procedures and/or processes to address regulatory requirements, and challenging the implementation plan as needed; ensures a comprehensive regulatory inventory

Identifies, aggregates, reports, escalates, inspects and challenges the remediation and thematic analysis of FLU/CF-owned issues and control enhancements related to financial crimes

Escalates financial crimes related compliance and operational risks and issues to appropriate governance routines, management/board level committees

Responsible for the remediation of financial crimes related C&OR owned issues and control enhancements to ensure they are addressed appropriately and timely

Participates in the development and maintenance of the global financial crimes coverage plan which defines the scope and risk-based focus of the second lines risk management activities and/or oversees execution of monitoring, testing, and risk assessments, communicate results

Reviews and challenges the FLU/CF process, risk, control (PRC) inventory and FLU/CF Risk & Control Self-Assessment (RCSA)

Reviews and challenges internal and external operational loss events, including development of remediation plans to strengthen controls, and approves where appropriate

Participates in Scenario Analysis activities for coverage areas and challenges as appropriate

Ensures metrics are designed to measure key risks and control performance, monitors and reports on metric performance and breach remediation



Additional activities may include:

Partners in the filing of all regulatory reports for the Company related to Financial Crimes

This role may have Money Laundering Reporting Officer responsibilities



Objective: The sanctions program execution risk manager is responsible for setting the enterprise sanctions risk management strategy, together with the GES Executive, and for overseeing implementation across Front Line Units.



Policies and Standards

Review Financial Crimes Policies and Standards and compare against 2nd line of defense activities to confirm coverage of key requirements

Monitoring & Testing

Provide enterprise overview of all sanctions-related monitoring & testing and perform thematic reviews

Propose and challenge changes related to sanctions monitoring & testing activities to ensure alignment with strategic

Issues

Manage GES owned issues

Provide enterprise overview of all sanctions-related issues and perform thematic reviews

Review new sanctions issues for appropriate theme/sub-theme classification and thematic concerns and recommend issue expansion and/or regrade of severity

Metrics and Reporting

Execute management reporting on key significant matters

Aggregate month end risk metrics and perform thematic reviews

Risk Assessment

Set, together with the GES Executive, the Risk Assessment strategy

Review periodic and targeted Risk Assessments to ensure alignment with the strategy

Participate in risk assessment calibration exercises

Strategy and Process Improvement

Define, together with GES Executive, the enterprise sanctions strategy, and oversee its implementation

Oversee works streams involving sanctions processes



Required Skills: Minimum Years Business & Functional Experience: 7 Years

Degree Required: Bachelors degree or equivalent experience



Desired Skills: Financial Services and/or related government entity



**Shift:**



1st shift (United States of America)



**Hours Per Week:**



40



Learn more about this role



Full time



JR-22064426



Band: H4



Manages People: No



Travel: No



Manager:



Talent Acquisition Contact:



Jeff Fey



Referral Bonus:



0



Bank of America and its affiliates consider for employment and hire qualified candidates without regard to race, religious creed, religion, color, sex, sexual orientation, genetic information, gender, gender identity, gender expression, age, national origin, ancestry, citizenship, protected veteran or disability status or any factor prohibited by law, and as such affirms in policy and practice to support and promote the concept of equal employment opportunity and affirmative action, in accordance with all applicable federal, state, provincial and municipal laws. The company also prohibits discrimination on other bases such as medical condition, marital status or any other factor that is irrelevant to the performance of our teammates.




To view the "EEO is the Law" poster, CLICK HERE (https://www.dol.gov/ofccp/regs/compliance/posters/pdf/eeopost.pdf) .


To view the "EEO is the Law" Supplement, CLICK HERE (https://www.dol.gov/ofccp/regs/compliance/posters/pdf/OFCCP\_EEO\_Supplement\_Final\_JRF\_QA\_508c.pdf) .



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To view Bank of Americas Drug-free workplace and alcohol policy, CLICK HERE .

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