Job Title: Head of Sanctions, Mashreq New York Compliance

Reports To: Money Laundering Reporting Officer (MLRO)

The Head of Sanctions will be responsible for leading Mashreq New York Sanctions Compliance Program. This role will oversee sanctions risk management, transaction screening operations, advisory support, and regulatory engagement while managing a team of compliance professionals.

The incumbent will ensure the Bank’s compliance with U.S. sanctions laws (including OFAC), applicable global sanctions regimes, and regulatory expectations, particularly as they relate to cross-border payments and USD clearing activities.

Key Responsibilities

1. Sanctions Program Management

• Design, implement, and continuously enhance the Bank’s enterprise-wide sanctions compliance program.
• Ensure alignment with OFAC regulations, U.S. regulatory expectations (e.g., Federal Reserve, OCC, NYDFS), and global sanctions frameworks.
• Maintain and periodically update sanctions-related policies, procedures, and controls.

2. USD Clearing & Correspondent Banking Oversight

• Oversee sanctions risk associated with USD clearing transactions and nostro/vostro activities.
• Provide subject matter expertise on correspondent banking risks and nested relationships.
• Ensure robust controls around cross-border payment screening, cover payments, and trade finance transactions.

3. Sanctions Screening Operations

• Manage end-to-end sanctions screening operations (payments, customers, trade transactions).
• Oversee alert disposition, escalation, investigation, and decision-making processes.
• Optimize screening systems, parameters, and data quality to reduce false positives while maintaining regulatory compliance.

4. Advisory & Risk Assessment

• Provide strategic sanctions advisory to business units, senior management, and new product initiatives.
• Conduct sanctions risk assessments for new clients, products, geographies, and transactions.
• Advise on complex sanctions scenarios, including potential matches, licensing considerations, and regulatory interpretation.

5. Regulatory Engagement & Governance

• Serve as the primary point of contact for regulators on sanctions-related matters.
• Manage regulatory exams, inquiries, audits, and remediation efforts.
• Prepare management reporting and present sanctions-related risks and metrics to senior committees (e.g., Board Risk Committee).
• Lead and oversee investigations into potential sanctions matches, violations, and control breakdowns across payments, trade finance, and customer activity.
• Ensure timely and well-documented decision-making for true matches, false positives, and escalations in accordance with OFAC regulations and internal policies.
• Oversee the identification, escalation, and resolution of potential sanctions breaches, including root cause analysis and control remediation.
• Ensure full compliance with OFAC requirements relating to:

6. Investigations & Issue Management

• Blocked property reporting (including initial and annual reporting obligations)
• Rejected transaction reporting
• Maintenance of accurate audit trails and supporting documentation for all sanctions-related decisions
• Direct and manage the preparation, review, and submission of Voluntary Self-Disclosures (VSDs) to OFAC, including:
• Assessing materiality and regulatory exposure
• Coordinating internal investigations across Legal, Compliance, and Business units
• Ensuring timely, accurate, and comprehensive submissions
• Act as a key escalation point for complex or high-risk sanctions matters, including dealings involving sanctioned jurisdictions, ownership structures (50% rule), or evasion typologies.
• Coordinate with Legal, Internal Audit, and senior management on sanctions-related incidents and ensure appropriate governance and reporting to regulatory bodies and internal committees.
• Drive lessons-learned exercises and implement corrective actions to strengthen controls and prevent recurrence of sanctions issues.

7. Team Leadership & Development

• Lead and manage a team of sanctions professionals (operations, advisory, and governance).
• Foster a strong compliance culture and provide ongoing training and development.
• Set performance objectives and ensure effective resource allocation.

8. Technology & Transformation

• Partner with technology teams to enhance sanctions screening tools and transaction monitoring systems.
• Drive automation, data analytics, and efficiency improvements in sanctions operations.
• Ensure systems are aligned with regulatory expectations and industry best practices.

Qualifications & Experience

Education

• Bachelor’s degree required; advanced degree (e.g., JD, MBA, or Master’s in relevant field) preferred.
• Professional certifications (e.g., CAMS, CGSS) strongly preferred.

Experience

• 10-15 years of experience in financial crime compliance, with significant focus on sanctions.
• Extensive experience in USD clearing, correspondent banking, or cross-border payments.
• Proven track record of managing sanctions programs within U.S. regulated financial institutions.
• Experience interacting with U.S. regulators (e.g., OFAC, Federal Reserve, NYDFS).

Skills & Competencies

• Deep knowledge of OFAC sanctions regulations and global sanctions regimes.
• Strong understanding of payment systems (SWIFT MT/MX), correspondent banking flows, and trade finance.
• Proven leadership and team management capabilities.
• Strong analytical and decision-making skills in high-risk scenarios.
• Excellent communication and stakeholder management skills.
• Ability to operate effectively in a fast-paced, high-pressure regulatory environment.

Key Success Factors

• Ability to balance regulatory compliance with business enablement.
• Strong judgment in complex sanctions decision-making.
• Proactive risk identification and mitigation.
• Effective engagement with regulators and senior leadership.
• Continuous improvement of operational efficiency and control effectiveness.

Salary Range :

Annual salary range $175k to $225k

Company