BNP Paribas Management has committed to ensure compliance with AML/Embargo & Sanctions rules within the entire Group. In this context, Group Compliance has decided to have a strong and permanent set-up within the US: Group Financial Security U.S. (“GFS U.S.”). The objectives of this unit include:
- Having the responsibility for the BNP Paribas Group framework in relation to compliance with US sanctions.
- Ensuring Sanctions Notices are disseminated in relation to US Sanctions in liaison with Legal.
- Issuing norms, policies, and procedures in relation to sanctions as applicable across the BNP Paribas Group.
- Providing advice on situations linked to US sanctions across the Group.
- Acting as the ultimate level of management of the US sanctions – related alerts.
- Acting as the sponsor of tools used to filter flows against embargo/sanctions lists.
- Risk assessing the Group’s branches & affiliates regarding non-compliance issues through a permanent risk oversight.
- Performing on-site controls within BNP Paribas Group to verify that BNP Paribas entities comply with norms issued by GFS U.S.
The OFAC Alerts Investigations (“OAI”) team serves as the Group’s Subject Matter Experts (“SME”’s) concerning U.S. economic sanctions. The team provides guidance to Group entities regarding U.S. economic sanctions issues and is the Group’s single point of contact with the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). All OAI team members are expected to have the ability to perform all team functions as necessary, although the team is functionally divided into two parts:
- Analyzes and dispositions OFAC transaction alerts escalated to OAI (the highest level of review at the bank) by Group businesses, operations, and compliance personnel globally.
· Administers and operates the Sanctions List Management Committee (“SLMC”), the Group-wide committee charged with overseeing the addition/modification/deletion of unlisted sanctions-related targets from Group filters.
- Drafts Sanctions Notices (covering OFAC list updates, regulatory developments, and guidance documents) for distribution globally.
· Manages OFAC reporting, including filing Block and Reject reports and the ARBP for all U.S. BNP Paribas Group entities.
· Provides guidance on U.S. / OFAC sanctions concerns raised by Group businesses, operations, and compliance personnel globally.
· Serves as the GFS U.S. stakeholder for global filtering, tuning, and other transactional process that impact the GFS U.S. remit.
· Works closely, in partnership with GFS Paris, with local and regional compliance teams and competency centers ensuring adherence to Group sanctions policies and procedures.
· Assists in training on OFAC sanctions topics dedicated to Group businesses, operations, and compliance personnel globally.
Business Overview Cont’d:
· Investigates apparent violations of U.S. / OFAC sanctions regulations, filing VSDs on behalf of BNP Paribas Group.
· Implements and provides day-to-day response to OFAC Interdiction Requests.
· Responds to OFAC RFI’s, including 602 Subpoenas and informal RFIs.
· Applies for and manages the implementation of OFAC specific licenses on behalf of BNP Paribas Group.
Candidate Success Factors:
Candidates are measured on the following four performance drivers, which will dictate how individual impact is considered on the Americas platform:
- Results and Impact
- Able to influence peers and team.
- Demonstrates good judgement when making decisions of high complexity and impact.
- Exercise appropriate autonomy in the execution and delivery of work.
- Responsible for driving outcomes, which have meaningful effect on team or department.
- Leadership and Collaboration:
- Creates trust with colleagues.
- Acts in leadership capacity for projects, processes, or programs.
- Client, Customer and Stakeholder Focus:
- Able to build relationships with a mix of colleagues and clients.
- Interacts regularly with management and department leaders.
- Demonstrates the ability to influence stakeholders at the team level.
- Compliance Culture and Conduct:
- Takes full responsibility for personal actions and demonstrates courage in facing problems and conflicts.
- Perceived as a person of high moral character; upholds corporate values and displays high ethical standards.
The Alerts Analyst has primary responsibility, under the supervision of the Alerts Manager, for day-to-day work to:
- Analyze and disposition OFAC transaction alerts escalated to OAI (the highest level of review at the bank) by Group businesses, operations, and compliance personnel globally.
- Administer and operate the Sanctions List Management Committee (“SLMC”) (including review of the submissions of names for the internal lists for consideration by the SLMC and preparing and distributing the agenda and minutes for the SLMC meetings).
- Participate in other related internal tools and other alerts management governance committees.
- Draft Sanctions Notices (covering OFAC list updates, regulatory developments, and guidance documents) for distribution.
- Review the Annual Report of Blocked Property/weekly submission of blocks/rejects to OFAC.
- Generate metrics on OAI team activities and prepare OAI team statistics for GFS Management, Executive Committees, and regulators.
- Represent OAI team on, and participate in, the work-streams of various GFS projects related to the OAI team’s areas of responsibility, including in relation to the filtering tool and its functionalities.
- Review and update internal desk procedures for the OAI team’s areas of responsibility.
- Keep abreast of new U.S. sanctions regulations, enforcement actions and penalties.
In addition, the Alerts Analyst assists the Alerts Manager and senior OAI team members in:
· Providing guidance on OFAC sanctions transactional issues and inquiries raised by Group businesses, operations, and compliance personnel globally.
· Performing analysis and investigation of matters under the OAI team’s responsibility (such as OFAC licenses; OFAC VSDs; OFAC list management issues; OFAC RFIs (formal/informal) including OFAC Interdiction Requests and entering related case data in OAI’s case management systems.
· Acting as an OFAC SME, participate in training programs and provide guidance and feedback on OFAC sanctions issues in sanctions-related documents (internal procedures, training decks, guidance documents, etc.).
Minimum Required Qualifications:
· Undergraduate degree.
· 2 – 3 years’ experience in a banking or financial regulatory environment.
o 1 – 2 years’ experience in Sanctions Compliance.
· Knowledge of:
o National and international payment systems.
o US-Sanctions regime and operational impacts.
· Knowledge of banking products & services.
· Strong computer skills and analytical and investigative skills.
· High ethical standards.
· Flexibility to adapt to a new and changing environment.
· Strong verbal and written communication skills and a high level of detail orientation and organization.
· Ability to work well with others, particularly with individuals across a global organization, in a fast-paced environment.
- Finance, legal/public policy administration, international affairs, or business-related majors a plus.
- Graduate degree a plus.
- French language skills a plus.
· Knowledge of BNP Paribas Group activities and organization a plus.
FINRA Registrations Required:
- Not Applicable
CFTC Swap Dealer Associated Person (if yes, NFA Swaps Proficiency Program is required):
- Not Applicable
SEC Security-Based Swap Dealer Associated Person:
- Not Applicable
The expected starting salary range for this position is between $112,000 to $137,000 annually. The actual salary may vary based upon several factors including, but not limited to, relevant skills/experience, time in role, base salary of internal peers, prior performance, business line, and geographic/office location.
In addition, our comprehensive benefits package aims to support our employees in various aspects of their lives. From healthcare and wellness programs to retirement plans and childcare services, we prioritize the well-being and growth of our employees. Our benefits include medical, dental and vision coverage, a 401(k) Savings Plan, backup childcare, life, accident and disability insurance, mental health support and paid time off. Additional details about our benefits offerings, inclusive of eligibility for a discretionary bonus, will be provided during the hiring process.
This application will remain open until a candidate has been selected for the role. There is no specific application timeline.
About BNP Paribas:
BNP Paribas is a leading bank in Europe with an international reach across the US, EMEA and APAC. It has a presence in 65 countries, with nearly 190,000 employees. The bank employs over 3,500 people in offices in the US across 10 states including New York, Jersey City, Chesterbrook, PA, San Francisco, Boston, Chicago, Denver, Miami, and Washington, DC. BNP Paribas has built a strong and diversified presence to support its client base. We continue to grow and strengthen our commitment to the US market through our Corporate & Institutional Banking activities. We are one of a few non-US banks to offer a full value chain for our clients, from trading to financing, and clearing and custody in the US with the international footprint and capacity to deliver both globally and locally. Leveraging the strength of our European roots, our network can support clients in virtually every region of the world, enabling more connectivity and efficiency wherever our clients conduct business. We take pride in our expertise and our ability to adapt while constantly looking ahead to create a more sustainable world.
As an international company with a global footprint, the unique cultures and viewpoints of our team members are an integral part of the fabric of BNP Paribas. We are a company with a purpose – to be a responsible and sustainable global leader. We aim to create an environment where our employees feel empowered to drive change, make an impact and be true to themselves. We employ talented individuals from a wide variety of backgrounds, locally and globally, and are inspired by our employees who help us in cultivating a diverse, equitable and inclusive workplace through initiatives such as our Diversity, Equity & Inclusion (DEI) Leadership Forum and Employee Resource Group (ERG) communities. We strive to be a workplace where all team members can grow and thrive and offer robust training, development, and mentoring opportunities to make that vision a reality. Our leaders are deeply committed to DEI and highly accessible to our employees, consistently soliciting feedback on how we can continue to support our employees to reach their highest potential.
BNP Paribas. The Bank for a Changing World – https://usa.bnpparibas/en/homepage/join-us/our-opportunities/
BNP Paribas is committed to providing a work environment that fosters diversity, inclusion, and equal employment opportunity without regard to race, color, gender, age, creed, sex, religion, national origin, disability (physical or mental), marital status, citizenship, ancestry, sexual orientation, gender identity and gender expression, or any other legally protected status.