Regional Head of Sanctions

The Regional Head of Sanctions & Embargoes (“HoS”) has responsibility for the Asia Pacific region in assisting the Regional Head of Financial Crime Unit (“FCU”) in maintaining the SG Group FCU Policy standards on Sanctions and Embargoes (“S&E”); ensuring SG Group remains regulatory compliant in all FCU S&E related matters.

In particular, the post holder will be one of the subject matter experts within the APAC Regional S&E team, providing S&E expert advice to the business lines and support functions on a day-to-day basis.

The post holder is also expected to help implementing S&E policies and procedures, keep senior management informed of S&E related matters and risks, contribute to the training and awareness program and undertake ad hoc projects to enhance on an ongoing basis the Sanctions Compliance program.

Responsibilities

The Head of Sanctions serves as the primary S&E subject matter expert and is responsible for implementing and overseeing the controls and operations of the Sanctions Compliance program for the Asia Business Unit ("BU"). The Head of Sanctions reports hierarchically to the Regional Head of FCU, APAC and functionally to the Deputy Head of Group Sanctions Compliance (CPLE/FCC/EMB). The Head of Sanctions role includes the following from S&E compliance perspective and by reference to the Asia BU:

Normative Framework

• Ensure implementation of the Group Sanctions Policy and Procedure;
• Draft and distribute other S&E related policies/procedures, where needed;
• Define asset freezing control framework, and notify Group Sanctions Compliance of frozen accounts;
• Provide advice regarding the correct implementation of policies or regulations;
• Supervise the implementation of sanctions compliance framework across the Asia BU and ensure the above missions are achieved at Asia BU / entities level.

Filtering Process

• Have an oversight on the local filtering tool, if applicable;
• Identify the databases/ transactions systems which must be filtered;
• Develop any filtering action plans aimed at enhancing the filtering process, if applicable;

Deal Flow & Advisory

• Monitor S&E related information received from SG entities within the Asia BU and advise on escalated customer files and transactions (including trade finance transactions, syndicated loans, debt issuances etc.) in accordance with the Group Sanctions escalation criteria, and where applicable further escalate such files and transactions to Group Sanctions Compliance;
• Escalate to Group Sanctions Compliance all files that require contact with the French Treasury in France or OFAC in the U.S.;
• Provide technical advice on S&E matters (e.g. on Dispensations, New Product Committees, filtering), liaise with Group Sanctions Compliance as and when needed

Alert Management

• Analyze and follow up on the processing of Level 2 Alerts (transactional and referential) that are escalated to Regional Sanctions and Embargoes team, APAC and determine whether these alerts should be escalated to Group Sanctions Compliance in accordance with the Group Sanctions escalation criteria (when these Level 2 Alerts are not directly escalated to Group Sanctions Compliance);

Oversight & Governance

• Coordinate with Asia BU entities through an appropriate governance;
• Perform follow-up of designated individuals and entities and support to the deployment of S&E requirements;
• Monitor Financial Crime Committees of SG entities for consistency with Group Sanctions Compliance’s guidelines on run-the-bank committees, including ensure proper reporting of Management Information (KRI/KPI) to local management via adequate committees;
• Contribute and attend to S&E related committees both at Regional and Group levels and represent the APAC Regional S&E team in other governance forums as and when needed;
• Contribute to relevant regulatory reporting made by Group Sanctions Compliance through the consolidation of relevant information escalated by entities;

Risk Assessment

• Lead the Compliance Risk Assessment exercise (“COMPASS”) and contribute to writing and review of the report for the BU;
• Assess Sanctions risk within the BU and escalate areas of risks and mitigated measures;
• Provide advice in view of New Product Committees to conduct sanctions risk assessment;
• Check and challenge actions taken at entity level to manage sanctions risks based on COMPASS;

Training

• Deploy the Group Sanctions Training Plan;
• Deliver targeted S&E Training to SG employees;

Other

Ensuring an adequate level of resources, both from a qualitative and quantitative standpoint, necessary to the good functioning of the Sanctions Compliance program through completion of the Group S&E capacity planning exercise.

PROFILE REQUIRED
Academic Background and Certifications, ExperienceEducation

• Graduate level with legal or other relevant professional qualification is required;
• ACAMS Certified Global Sanctions Specialist ("CGSS");

Recommended experience

• Minimum 8 years’ experience in Compliance, dedicated to Financial Crime topics with a focus on Sanctions;

Languages

• Fluent written and spoken English

Technical skills

• Strong knowledge of the sanctions regulatory environment in the financial sector and of EU, OFAC and UN sanctions;
• Strong knowledge of S&E control techniques;
• Strong knowledge of compliance risks management and analysis;
• Knowledge of the entity / branch, its products and markets.

Management Skills

Managerial experience with high-risk awareness
Proven experience in dealing with highly sensitive and confidential material;
Ability to discuss with the business (adopting an independent partner posture, while understanding concerns), of having convictions and keeping them, and ability to explain its positions;
Autonomy, ability to make decisions, rigor;
Integrity, exemplarity;
Coordination, animation, convincing and motivating skills

Behavioral Skills

• Team Spirit - Open mindset: I listen and share my views and my expertise in an open mode
• Team Spirit - Collective mindset: I favour the team’s interest over my own results
• Client - Risk: I strive to satisfy clients while taking into account risks for the company
• Commitment - Exemplarity: I embody the Group’s values
• Responsibility - Risk awareness: I am constantly on the lookout for risks
• Innovation - Change management: I support changes
  We regret to inform that only shortlisted candidate will be notified

Company Description

Societe Generale is one of the leading European financial services groups. Based on a diversified and integrated banking model, the Group combines financial strength and proven expertise in innovation with a strategy of sustainable growth. Committed to the positive transformations of the world’s societies and economies, Societe Generale seeks to build together with its clients, a better and sustainable future through responsible and innovative financial solutions. Active in the real economy for over 150 years, with a solid position in Europe and connected to the rest of the world, Societe Generale has over 117,000 employees in 66 countries and supports 25 million individual clients, businesses and institutional investors worldwide (figures as of August 2023). We have a presence in 11 locations across Asia Pacific. With our regional headquarters in Hong Kong – a core hub of the worldwide Societe Generale Group – we employ around 2,300 employees in the region. In addition, Societe Generale's Global Solution Centre (SGGSC) in Bangalore and Chennai supports the Group in Asia Pacific and globally with customised business solutions.

For more information, follow us on LinkedIn @Société Générale or visit our website www.societegenerale.asia.

Department Description

Sanctions Compliance within the FCU is responsible for ensuring compliance with OFAC, E.U., and other applicable sanctions programs throughout Asia BU. Sanctions Compliance is responsible for reviewing alerts on transactions (second level review) and static data (second level review) for potential matches to the OFAC, E.U., UN and any other applicable lists; reporting blocked property and rejected transactions; investigating and drafting Incident Reports to be escalated to Group Sanctions Compliance (FCC/EMB); delivering targeted training to SG Employees as per SG Sanctions Training Plan including on OFAC sanctions issues; providing sanctions-related advisory support to entities within the Asia BU; reviewing and approving the Sanctions Risk Assessment, and coordinating with the Group Sanctions Compliance, as appropriate.