Senior Counsel, Sanctions & AML
[**员工申请人隐私通知**]https://www.sofi.com/sofi-employee-applicant-privacy-notice/) **我们是谁：** 塑造一个更光明的金融未来与我们一起。我们和我们的成员在一起，我们正在改变人们对个人财务思考和互动的方式。我们是一个下一代的金融服务公司和国家银行，使用创新技术，首先移动技术帮助数百万个成员实现他们的目标。该行业正在经历前所未有的转型，我们处于领先地位。我们自豪地每天来工作，知道我们所做的有直接影响到人们的生活，并以我们的核心价值观指导我们。**加入我们，投资于自己，你的职业生涯和金融世界.****角色：** SoFi 正在寻找一个经验丰富的经济制裁和反洗钱 (AML) 的高级律师，加入法律团队。这个律师将成为该公司在外国资产控制办公室 (OFAC) 管理的美国制裁方面的专家。他们还会咨询银行保密法 (BSA) 和 AML 要求在 SoFi 的产品和行业领域中。这位角色与合规，BSA/AML 官员，风险，产品，工程，运营和财务犯罪团队紧密合作。它也支持联邦银行监管机构和 OFAC 的监管审查和参与。**你将做什么：** - 作为 OFAC 制裁计划的首席法律顾问，包括国家和名单上的制裁，50%规则，部门制裁和次级制裁风险。- 在实践中对制裁选，封锁，拒绝和报告义务的工作方式提供建议。这包括被阻止财产的报告，被拒绝交易报告以及被阻断财产的年度报告。- 评估可能违反的制裁行为。领导内部调查并向 OFAC 根据经济制裁执行指南自愿披露自我信息。- 准备并提交特定许可要求，解释性指导请求和其他函授给 OFAC. 咨询一般许可证的应用方式。- 咨询 BSA/AML 要求，包括客户尽职调查 (CDD),实际所有权，客户识别计划 (CIP),可疑活动报告 (SAR),货币交易报告 (CTR),记录和 FinCEN 要求。- 审查和建议 SoFi 的制裁和 AML 政策，程序，风险评估和选方法。与 Compliant 合作伙伴
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[**Employee Applicant Privacy Notice**](https://www.sofi.com/sofi-employee-applicant-privacy-notice/)
**Who we are:**
Shape a brighter financial future with us.
Together with our members, we’re changing the way people think about and interact with personal finance.
We’re a next-generation financial services company and national bank using innovative, mobile-first technology to help our millions of members reach their goals. The industry is going through an unprecedented transformation, and we’re at the forefront. We’re proud to come to work every day knowing that what we do has a direct impact on people’s lives, with our core values guiding us every step of the way. **Join us to invest in yourself, your career, and the financial world.**
**The role:**
SoFi is looking for a Senior Counsel with deep experience in economic sanctions and anti-money laundering (AML) to join the Legal team. This attorney will be the company's go-to legal expert on U.S. sanctions administered by the Office of Foreign Assets Control (OFAC). They will also advise on Bank Secrecy Act (BSA) and AML requirements across SoFi's products and lines of business. The role works closely with Compliance, the BSA/AML Officer, Risk, Product, Engineering, Operations, and Financial Crimes teams. It also supports regulatory examinations and engagement with federal banking regulators and OFAC.
**What you'll do:**
- Act as the lead legal advisor on OFAC sanctions programs, including country-based and list-based sanctions, the 50 Percent Rule, sectoral sanctions, and secondary sanctions risk.
- Advise on how sanctions screening, blocking, rejecting, and reporting obligations work in practice. This includes blocked property reports, rejected transaction reports, and annual reports of blocked property.
- Assess possible sanctions violations. Lead internal investigations and advise on voluntary self-disclosures to OFAC under the Economic Sanctions Enforcement Guidelines.
- Prepare and submit specific license requests, interpretive guidance requests, and other correspondence to OFAC. Advise on how general licenses apply.
- Advise on BSA/AML requirements, including customer due diligence (CDD), beneficial ownership, Customer Identification Program (CIP), suspicious activity reporting (SAR), currency transaction reporting (CTR), recordkeeping, and FinCEN requirements.
- Review and advise on SoFi's sanctions and AML policies, procedures, risk assessments, and screening methods. Partner with Compliance to keep the program effective and in line with regulatory expectations.
- Give legal guidance on new products, features, partnerships, and markets, such as payments, cross-border activity, digital assets, and fintech partnerships. Identify sanctions and AML risks and practical ways to reduce them.
- Support regulatory examinations, inquiries, and enforcement matters with the OCC, Federal Reserve, FinCEN, OFAC, and other agencies.
- Review and negotiate sanctions and AML provisions in vendor, partner, and commercial agreements.
- Track legislative, regulatory, and enforcement developments, including new sanctions designations, AML Act rulemakings, and enforcement trends. Explain their impact clearly to business stakeholders and senior leaders.
- Create and deliver training on sanctions and AML legal requirements for internal teams.
- Manage outside counsel on sanctions and AML matters.
**What you'll need:**
- J.D. from an ABA-accredited law school, with active membership in good standing in at least one U.S. state bar.
- 7 to 10 years of legal experience, with substantial and direct focus on U.S. economic sanctions (OFAC) and BSA/AML regulation.
- Specific, demonstrated OFAC expertise, including:
- In-depth knowledge of OFAC regulations (31 C.F.R. Chapter V), sanctions programs, and enforcement practice.
- Hands-on experience preparing license applications, voluntary self-disclosures, and responses to OFAC subpoenas or administrative inquiries.
- Experience advising on screening, blocking and rejecting decisions, and sanctions compliance program design consistent with OFAC's _A Framework for OFAC Compliance Commitments_.
- Strong working knowledge of the BSA, the USA PATRIOT Act, the Anti-Money Laundering Act of 2020, and FinCEN regulations.
- Experience advising banks, broker-dealers, money services businesses, fintech companies, or other regulated financial institutions.
- Excellent judgment, with the ability to turn complex legal requirements into clear, practical, risk-based advice for non-lawyers.
- Strong written and oral communication skills, including experience presenting to senior leaders.
- Ability to work independently and handle several priorities in a fast-paced environment.
**Preferred qualifications:**
- Prior work at OFAC (for example, in the Office of Compliance and Enforcement, Licensing Division, Office of the Chief Counsel (Foreign Assets Control), or a sanctions policy role), or at the U.S. Department of the Treasury in a sanctions-focused role. **Strongly preferred.**
- Experience in the sanctions, AML, or financial regulatory practice of a leading law firm, **or** previous in-house experience at a bank, fintech, or other regulated financial services company. Candidates who combine OFAC government service with law firm or in-house experience are especially encouraged to apply.
- Experience with digital assets, payments, or cross-border transaction sanctions issues.
- Experience with the export control laws (EAR) and their overlap with sanctions compliance.
- Familiarity with sanctions screening technology, transaction monitoring systems, and vendor management.
- Experience supporting regulatory examinations by federal banking regulators.
**Compensation and Benefits**
The base pay range for this role is listed below. Final base pay offer will be determined based on individual factors such as the candidate’s experience, skills, and location.
To view all of our comprehensive and competitive benefits, visit our **[Benefits at SoFi](https://sofietyinfo.sofi.com/sofi-benefits)** page!
##### SoFi provides equal employment opportunities (EEO) to all employees and applicants for employment without regard to race, color, religion (including religious dress and grooming practices), sex (including pregnancy, childbirth and related medical conditions, breastfeeding, and conditions related to breastfeeding), gender, gender identity, gender expression, national origin, ancestry, age (40 or over), physical or medical disability, medical condition, marital status, registered domestic partner status, sexual orientation, genetic information, military and/or veteran status, or any other basis prohibited by applicable state or federal law.
##### The Company hires the best qualified candidate for the job, without regard to protected characteristics.
##### Pursuant to the San Francisco Fair Chance Ordinance, we will consider for employment qualified applicants with arrest and conviction records.
##### [New York applicants: Notice of Employee Rights](https://dol.ny.gov/system/files/documents/2022/02/ls740_1.pdf)
##### SoFi is committed to an inclusive culture. As part of this commitment, SoFi offers reasonable accommodations to candidates with physical or mental disabilities. If you need accommodations to participate in the job application or interview process, please let your recruiter know or email [accommodations@sofi.com.](mailto:accommodations@sofi.com)
##### We are unable to accommodate remote work from Hawaii, Alaska or Puerto Rico at this time.
**Internal Employees**
If you are a current employee, do not apply here - please navigate to our Internal Job Board in Greenhouse to apply to our open roles.