Associate General Counsel, Compliance, Americas

THE ROLE

This role will be based in New York reporting to the Chief Compliance Officer and Deputy General Counsel, Global Head of Litigation and will assist with developing, implementing and managing all aspects of compliance in the Americas, including providing advice to business groups and senior stakeholders on compliance related matters affecting Sotheby’s business in these regions. 

To be successful in this role, the individual must be a qualified lawyer with extensive experience in all areas of compliance, including financial crime.  They should have exemplary communication skills and experience in designing and implementing cross-border compliance programmes.  They will also have the ability to build strong relationships with our business clients and senior stakeholders, and to give considered and practical advice on complex matters.  The right person for this role will be a self-starter who has sufficient expertise and experience in this area to be able to operate autonomously.  

RESPONSIBILITIES

• Responsible for financial crime compliance in the Americas, including in relation to anti-money laundering and counter terrorist and proliferation financing (AML/CTPF), sanctions and anti-bribery and corruption (ABC) and corporate offences, and will work with colleagues in the Compliance Department in relation to financial crime compliance in other regions, including EMEA & Asia;
• Assisting with developing, maintaining and keeping under review, Sotheby’s business wide risk assessments, policies and procedures in relation to financial crime, including AML/CTPF, sanctions and ABC, and in relation to corporate offences;
•  Responsible for the continuous development, improvement and implementation of Sotheby’s systems controls, policies, procedures and tools to mitigate financial crime and other risk, and partnering with Sotheby’s Service Operations, Product & Technology and Information Security teams on the same;  
• Act as point of escalation to advise on and assist with the onboarding of new clients and review of existing clients and their transactions, including regarding collection and review of client due diligence documents and screening results; resolution of screening results through automated tools (primarily, LSEG Worldcheck); review of existing client due diligence documents and ongoing screening; review and investigation of high-risk clients and transactions; and overseeing enhanced due diligence and recommendations to local senior management on approval of client onboarding or transactions;
• Oversight of regulatory affairs in the Americas, including for example, FCA related matters, acceptance of crypto-currencies and sale of non-fungible tokens (NFTs), and advising on and managing related policies, procedures and escalations;Supporting with any reporting or filing requirements that fall within the remit of the Compliance department, and on any regulator audit or risk assessment or other relevant government or regulator engagement;
•  Maintaining in-depth knowledge of relevant financial crime and corporate offence regulations, laws and regimes, and updating relevant staff on any relevant changes and best practices;
• Assisting with developing, maintaining, and delivering an education and training programme to inform employees on financial crime and other legal, regulatory and ethical matters that exist or which are likely to become relevant and which fall withing the remit of the Compliance Department, and maintenance of training records for the same;
• Assisting with maintaining Sotheby’s Code of Business Conduct and non-financial crime compliance policies and procedures (including, for example, anti-trust and conflicts of interest) to ensure that the company and its employees have sufficient information and guidance to allow them to comply with applicable laws and regulations and company-wide policies and ethical standards;
• Providing accurate and timely advice and guidance to Sotheby’s staff on issues arising from compliance policy areas and subject matters within the responsibility of the Compliance Department;
•  Assisting with designing and implementing procedures to monitor and audit the efficacy of the Compliance program, detect issues, violations and areas for improvement relating to policies or legal, regulatory or ethical requirements;
• Supporting senior stakeholders on larger projects by providing assistance and advice in connection with compliance related aspects;
• Taking an active role in knowledge sharing, thought leadership and practice development to ensure Sotheby’s remains abreast of developments in or updates to laws, regulations and practices in relation to financial crime and corporate offences, and assisting with the same for other matters falling within the remit of the Compliance Department;
• Ensuring appropriate record retention and management. 

• Implement Sotheby’s Code of Business Conduct, policies, procedures, manuals and internal codes that have been adopted by the Company, to ensure that Sotheby’s and its employees are at all times in compliance with applicable laws, regulations and company-wide policy and ethical standards, which relate to any of Sotheby’s existing Compliance policies.
• Maintain a comprehensive understanding of the legal and regulatory environment, requirements and developments relating to and impacting Sotheby’s business activities worldwide. Monitor and maintain accurate and up to date knowledge of, and updating policies as needed, concerning subject matter areas under the responsibility of the Global Compliance department, which include:
• The transparent and fair conduct of auctions and private sales;
• Due diligence relating to property and clients;
• Anti-money laundering and government sanctions;
• Anti-bribery and corruption (such as the FCPA, UK Bribery Act);
• Antitrust;
• Conflicts of interest;
• Cultural property/heritage matters;
• Endangered species;
• Data protection and information privacy
• Information security
• Develop, maintain and deliver an education and training program to inform employees on legal, regulatory and ethical matters that exist or may evolve and come under the responsibility of the Compliance Department, and to update relevant staff on any relevant changes.
• Provide timely and accurate advice and guidance to Sotheby’s staff on issues arising from compliance policy areas and subject matter within the responsibility of the Compliance Department.
• Design and implement procedures, including internal audits, in order to detect at the earliest time possible any violations of Sotheby’s policies or legal, regulatory or ethical requirements, including the conduct of internal investigations as required to address any questionable incidents or practices.
• Provide guidance and oversight of compliance to monitor the efficacy of the Compliance program, detect issues, violations and areas for improvement relating to policies or legal, regulatory or ethical requirements. This includes, where appropriate, directing and performing Compliance audits.
• Monitor legislative and regulatory developments and participate in industry lobbying efforts impacting the market.

IDEAL EXPERIENCE & COMPETENCIES

• Bachelor’s Degree and JD (must have State Bar admission in New York).
• 8+ years of professional experience at a large or boutique law firm; 3+ years of in-house experience is a plus.
• The ideal candidate will have previous experience of implementing cross-border compliance programmes and experience of financial crime compliance, including;
• Proficiency and experience in using relevant screening tools (for example, LSEG Woldcheck, Dow Jones, Lexis Nexis);
• Experience in transaction monitoring, in particular of block chain transactions, and fraud detection;
• Excellent analytical and written skills are vital, able to produce clear, high-quality writing; advanced communication and presenting skills are also important;
• Ability to assess and balance commercial and regulatory risks, to think strategically and to clearly and concisely provide advice, often in time pressured circumstances;
• Ability to provide clear guidance and workable, commercial solutions on complex and sensitive issues;
• Excellent relationship management and people skills, experience of managing a team, team player mentality with the ability to work alongside colleagues, and with clients, their representatives and other stakeholders;
• Maintaining excellent stakeholder management and communication skills with the ability to bring all stakeholders on board.
• Professional and calm manner; able to multi-task and prioritise and capable of working independently across Europe, the Middle East and Asia, and accommodating of other time zones when necessary;
• Additional language skills helpful;
• Art law / art industry experience is not required.

The proposed base salary for this position ranges from $175,000-$200,000. In addition to base salary successful candidates are eligible to receive a discretionary bonus, as well as a competitive benefits package. Salary offers are based on a wide range of factors including relevant skills, training, experience, education, and, where applicable, licensure or certifications obtained. Market and organizational factors are also considered.