Senior AML Compliance Officer – Abc – & Sanctions

Senior AML Compliance Officer – Abc – & Sanctions

Requirements

• Bachelor’s Degree, Law degree is preferred
• 10+ years investment advisor compliance experience
• Knowledge of the Patriot Act, Bank Secrecy Act, Investment Advisors Act of 1940 and related rules are needed, and knowledge of the Investment Company Act of 1940 is preferred
• Knowledge of international sanctions and bribery/corruption risk areas is preferred
• Knowledge of AML/KYC requirements and best practices related to corporate financing transactions

Responsibilities

• Supervise 2 or more compliance officers
• Analyze and opine on potential implications under the Investment Advisors Act of 1940 and Investment Company Act of 1940 for investing in transactions originated and structured by Guggenheim and by third party investment banks or other channels
• Maintain reporting and documentation as appropriate
• Maintain relationships with sector desks, PMs, traders, Legal and Operations etc. to understand proposed transactions and provide compliance guidance
• Perform post-transaction surveillance and reporting tasks
• Monitor international sanctions daily updates including identifying new sanctioned issuers
• Evaluate and if appropriate, add new sanctioned issuers to restricted lists
• Review escalations of potential AML/KYC/ABC risks from Accounts Payable, Human Resources and other business areas and provide direction
• Review invitees to Guggenheim events by all businesses that are escalated by Corporate Events teams or individual businesses to identify public officials and determine if transparency letter or other conditions are required for attendance
• Review business travel to high-risk countries
• Assist Global AML Head in conducting due diligence research where needed
• Review specific G&E requests where employees seek to provide G&E to a public official
• Coordinate and assist in the testing set forth in the Global AML teams’ Control Framework suite of 8 key control tests to include: (a) quarterly testing to identify if an employee failed to obtain preapproval before providing G&E to a public official; (b) annual testing of intermediaries including reviewing expenses to ensure consistent with their engagement agreement; (c) annual testing of High Risk country business travel to identify if preapproval was obtained and form completed
• Conduct weekly checks to ensure WorldCheck users have resolved sanctions hits within 7 calendar days as required by policy
• Administer Worldcheck for all firm users
• Assist Global AML Head with political contributions program
• Reviews weekly employee trading reports to verify if any trades involved low priced securities or sanctioned issuers
• Assists in presenting the monthly Global AML meetings.

Preferred Qualifications

• Strong communication skills, attention to detail, ability to multi-task and the ability to be effective in a fast-paced environment are critical
• Ability to work with other offices and periodic travel, as needed
• Be proactive & solutions-oriented; innovative; responsive to client needs; collaborative and energized by the open exchange of ideas
• Adapt quickly and appropriately in accordance with the constant evolution of the company and industry