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Assistant Vice President- Sanctions Risk Analyst / Investigator

Horaires Temps plein
Métier Risques
Marque BNP Paribas Personal Finance
Niveau d'expérience 1 à 2 ans
Niveau d'études Niveau BAC+2/3
Postuler REF: GRO000191
About BNP Paribas:

BNP Paribas Group

BNP Paribas is a leading bank in Europe with an international reach. It has a presence in 75 countries, with more than 189,000 employees, including more than 146,000 in Europe. The Group has key positions in its three main activities: Domestic Markets and International Financial Services (whose retail-banking networks and financial services are covered by Retail Banking & Services) and Corporate & Institutional Banking, which serves two client franchises: corporate clients and institutional investors. The Group helps all its clients (individuals, community associations, entrepreneurs, SMEs, corporate and institutional clients) to realize their projects through solutions spanning financing, investment, savings and protection insurance. In Europe, the Group has four domestic markets (Belgium, France, Italy and Luxembourg) and BNP Paribas Personal Finance is the leader in consumer lending. BNP Paribas is rolling out its integrated retail-banking model in Mediterranean countries, in Turkey, in Eastern Europe and a large network in the western part of the United States. In its Corporate & Institutional Banking and International Financial Services activities, BNP Paribas also enjoys top positions in Europe, a strong presence in the Americas as well as a solid and fast-growing business in Asia-Pacific.


Group Financial Security US Business Overview:

The management of BNP Paribas has committed to ensure compliance with AML, embargo & Sanctions, and KYC rules across the entire Group. In this context, Group Compliance has installed a permanent, robust US-based Sanctions compliance control team in New York: Group Financial Security US (“GFS-US”). The objectives of this unit include:

  • Responsibility for the BNP Paribas Group framework in relation to compliance with US Sanctions
  • Acting as the ultimate level of management of US Sanctions related alerts
  • Ensuring the effectiveness of a complete legal and regulatory watch function in relation to US Sanctions through liaison with Legal Affairs
  • Issuing norms, policies and procedures, and training in relation to Sanctions issues applicable across the BNP Paribas Group (focus of the GFS-US Norms and Procedures team)
  • Performing a Group-wide advisory function and supplying advice to business and compliance units for situations related to US Sanctions (focus of the GFS-US OFAC / Sanctions Advisory team)
  • Acting as the sponsor of tools used to filter flows against embargo / Sanctions lists and a the final level of escalation and review of possible OFAC violations (focus of the GFS-US OFAC / Sanctions Alerts team)
  • Performing an on-site control function to verify that BNP Paribas entities comply with norms issued by GFS-US (focus of the GFS-US On-Site Controls team)
  • Performing Sanctions-based risk assessments for the Group’s branches & affiliates regarding and facilitating permanent risk oversight (focus of the GFS-US Risk Oversight team)
The GFS-US Risk Oversight team is entitled to receive, in accord with legal, regulatory, or privacy constraints, all relevant information and data contributing to a comprehensive evaluation of Sanctions risks facing BNPP.  The Risk Oversight team is also responsible for monitoring the implementation and results of recommendations and remediation plans resulting from GFS-US on-site reviews.  In partnership with counterparts in the GFS-Paris unit, the GFS-US Risk Oversight team has the following duties and responsibilities:
  • Defining, constructing, administering, and sponsoring the annual global OFAC / Sanctions risk assessment
  • Conducting ongoing OFAC / Sanctions risk monitoring of internal audit, regulatory, and incident reports and identifying and addressing issues in collaboration with other GFS-US teams
  • Contributing to the development, creation, and delivery of ongoing Sanctions risk monitoring reporting to Compliance management and various stakeholders
  • Receiving, analyzing and investigating escalations involving possible circumvention or evasion of OFAC / Sanctions laws and regulations and providing oversight for corrective actions designed to address Sanctions related issues
  • Monitoring and facilitating the review and analysis of outgoing payment message transparency across the Group
  • Reviewing negative news escalations and whistle-blower reports extracting relevant OFAC / Sanctions data for analysis and synthesis with ongoing risk monitoring and remediation efforts
Responsibilities of the Risk Oversight Sanctions Risk Analyst / Investigator:

Aligned with the GFS-US Risk Oversight team’s overall objective, the position requires the detection and analysis of bank-wide OFAC / Sanctions risk identified through self-reported risk assessments, Sanctions alerts, reports produced by permanent control functions and audit, reviews conducted by local regulators, and other incidents.  The main tasks assigned to the role will be to investigate escalated matters of potential evasion or circumvention of Sanctions, significantly contribute to ongoing OFAC / Sanctions risk monitoring and reporting work streams, assist with implementation, administration, and validation of the Annual Global OFAC / Sanctions Risk Assessment, and participate in the monitoring of payment message transparency.  Specific responsibilities include:

  • Receiving, reviewing, analyzing, and investigating reports of potential attempts or requests to circumvent or evade Sanctions laws, regulations, or Group policy including drafting of case reports, presentation of cases to the committee that decides whether BNPP is required to report such matters pursuant to plea agreement obligations, sending related referrals to other teams, and maintaining case information and statistics
  • Conducting all ongoing risk monitoring task:
    • Reviewing, analyzing, summarizing, and maintaining Sanctions-related qualitative data sources including internal audit reports, operational risk incidents, historic incidents, regulatory reports, and compliance control data
    • Mapping of qualitative OFAC / Sanctions risk items to relevant business units and Sanctions topics
    • Developing and assisting in the delivery of regular reporting resulting from the ongoing monitoring process
  • Contributing to the implementation of the overall OFAC/Sanctions risk oversight methodology for the bank to ensure correct and efficient risk identification
  • Monitoring of payment message transparency:
    • Operating the SWIFT payment data quality tool
    • Delivering alerts to operations partners
    • Tracking and reporting the review and (if necessary) remediation of identified issues by various stakeholders in the compliance and operations
  • Engaging in the Annual Global OFAC/Sanctions Risk Assessment process:
    • Assisting in developing survey questions, responses, and format
    • Mapping survey questions to existing policies and procedures, regulatory recommendations, as well as previous survey questions
    • Participating in survey review and quality control phases
    • Answering questions from and providing guidance to compliance representatives from other business units
    • Involvement in the drafting, and editing of the annual Risk Assessment report
  • Developing and maintaining documentation and/or desktop procedures in regard to various Risk Oversight work streams

Minimum Required Qualifications:

  • 2+ years of experience in compliance / risk / controls environment   
  • Bachelor’s Degree 

Preferred Qualifications

  • Strong writing skills
  • Strong communication skills with comfort presenting to a senior audience
  • High level of proficiency with MS Office Suite (Word, Excel, PowerPoint, Visio)
  • Experience with data visualization using any or all of the following: Tableau, R, Excel
  • Exposure to drafting, validating, and/or maintaining policies and procedures
  • General knowledge of US Sanctions / OFAC regime
  • General knowledge of global banking products & services
  • High level of detail orientation and organization
  • Previous interaction with diverse data sets in order to create and deliver business or compliance reporting to stakeholders
  • Experience with payment systems
  • Experience with internal audit / controls
  • Experience with case management and survey systems
  • Experience with compliance risk assessments
  • Ability to manage several multi-faceted projects at once and meet tight deadlines
  • Ability to work well with others in a fast-paced environment
  • French language skills
FINRA Registrations Required:
  • Not Applicable 

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.


Primary Location: US-NY-New YorkJob Type: Standard / PermanentJob: MISCELLANEOUSEducation Level: Bachelor Degree or equivalent (>= 3 years)Experience Level: At least 2 yearsSchedule: Full-time Behavioural competency: Ability to collaborate / TeamworkTransversal competency: Ability to understand, explain and support change