Director, Financial Crime and Compliance, EMEA & Asia

THE ROLE

This role will be reporting to the Chief Compliance Officer and Deputy General Counsel, Global Head of Litigation and will be assist with developing, implementing and managing all aspects of compliance in EMEA & Asia, including providing advice to business groups and senior stakeholders on compliance related matters affecting Sotheby’s business in these regions.  This position will have a particular focus on financial crime compliance and will include undertaking the role of Money Laundering Reporting Officer (MLRO).  

To be successful in this role, the individual must be an experienced certified compliance professional or a qualified lawyer with extensive experience in financial crime compliance.  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 and to manage a team.

RESPONSIBLITIES

• Responsible for financial crime compliance in EMEA & Asia, 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 the US;
• Acting as MLRO and performing all associated responsibilities, including developing and managing Sotheby’s internal suspicious activity reporting processes and record-keeping, filing suspicious activity reports (SARs), filing annual returns and dealing with annual levies, and supporting on any regulator audit or risk assessment or other relevant government or regulator engagement;
• 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 risk, and partnering with Sotheby’s Service Operations, Product & Technology and Date Protection / Information Security teams on the same;
• Managing and developing Sotheby’s KYC Analyst team and equipping existing core operational functions at Sotheby’s (for example, pre-sale and post-sale teams and administrators) with adequate anti-financial crime awareness and compliance;
• 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 relevant region, 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;
• 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, conflicts of interest and property due diligence) 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, particularly in relation to financial crime;
• 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.

IDEAL EXPERIENCE & COMPETENCIES

• 8 plus years of either (a) compliance experience in the regulated sector with relevant qualifications (ICA AML certificate or Certified MLRO or CAMS); or (b) post-qualification experience in a regulatory and / or financial crime practice area at a leading UK or European commercial law firm (current in-house lawyers will be considered provided they have significant prior experience in private practice and currently work or have previously worked in the regulated sector);
• The ideal candidate will have previous experience of being an MLRO and / or of implementing cross-border compliance programmes, with a particular focus on financial crime compliance;
• Proficiency and experience in using relevant screening tools (for example, LSEG Worldcheck, 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.