Director – Head of Norms & Learning

BNP Paribas
  • Location
    New York, New York
  • Sector
    Commercial
  • Experience
    Mid Career / Advanced
  • Posted
    Jun 06

Position description

The Management of the BNP Paribas has committed to ensure compliance with Sanctions & Embargo regulations across the entire Group. In this context, Group Compliance has established a strong, permanent Domain in the United States called Group Financial Security U.S. (“GFS-U.S.”). The objectives of this Domain include:

  • Establishing and leading the BNP Paribas Group framework in relation to Compliance with US Sanctions, with authority to compel its compliance.
  • Ensuring a legal watch in relation to US Sanctions regimes - in liaison with Legal Affairs.
  • Publishing norms, policies and procedures in relation to Sanctions applicable across the BNP Paribas Group 
  • Providing advice on business situations linked to US Sanctions across the Group
  • Acting as the ultimate level of decision for US Sanctions related alerts,
  • Sponsoring tools used to filter flows, and screen databases against embargo / sanctions lists
  • Risk-assessing the Group’s branches & affiliates regarding non-compliance issues through permanent risk oversight
  • Performing on-site controls within BNP Paribas Group to verify that BNP Paribas entities comply with norms issued by GFS-NY.
  • Serving as liaison to the Bank’s Supervisors and Regulators for examinations, inquiries and communication on BNP Paribas’ compliance with U.S. Sanctions.

Responsibilities of the Norms and Learning (“NP&L”) unit:

The team is tasked with producing norms, policies and procedures relating to international sanctions – and the creation and delivery of global and targeted training– to ensure a robust and consistent sanctions control framework throughout the Group. 

  • Producing and maintaining policies and procedures relating to International Sanctions and associated topics, notably the Bank’s Global Sanctions Policy.
  • Producing the norms underlying the Bank’s Sanctions operational permanent control framework and ensuring coherence of the controls required for each line of defense.
  • Performing Sanctions-Related Product Risk Assessments and Sanctions Policy Derogation evaluations and responding to policy interpretation inquiries.
  • Liaising with Legal Affairs in the legal watch on US Sanctions for review and revision of norms, policies and procedures.
  • Driving the vision, design and delivery of Sanctions-related staff training, and training materials.
  • Animating the Bank’s Sanctions Compliance community, preparing and moderating its top-level governance bodies, and serving as permanent secretary to the Sanctions Committee
  • Contributing to Group compliance norms, policies & procedures in relation to AML, KYC and other transversal Financial Security matters.
  • Supporting the production of dashboards, presentations and reports.
  • Issuing Sanctions Notices and Guidance memos for clarification of Sanctions topics
  • Undertaking specific tasks and projects as required by the GFS U.S. General Manager.
  • Physical presence in BNPP’s office(s) is an essential function of this position. BNPP requires all of our employees to be vaccinated in order to access its offices, subject to reasonable accommodations for reasons related to disability or religion.

Candidate Success Factors:

Candidates to be measured on the following four performance drivers, which will dictate how individual impact is considered on the Americas platform:

  • Results and Impact 
    • Impacts division and influences peers and team
    • Demonstrates good judgement when making decisions of high complexity and impact
    • Relies on limited guidance for most complex decision making
    • Is responsible for driving outcomes which have meaningful effect on team or department
  • Leadership and Collaboration 
    • Creates trust with department leaders
    • Acts in leadership capacity for large projects, processes, or programs for a team
  • Client, Customer and Stakeholder Focus 
    • Able to build relationships with a mix of intermediate and senior colleagues or clients
    • Interacts regularly with management and department leaders
    • Demonstrates the ability to persuade and influence stakeholders at the team level
  • Compliance Culture and Conduct 
    • Takes full responsibility for personal actions and demonstrates courage in facing problems and conflicts
    • Perceived as a person of high moral character; upholds corporate values and displays high ethical standards”

Responsibilities: 

The Head of Norms & Learning is responsible for all the activities of the Norms and Procedures unit. The Head of Norms & Learning reports to the GFS U.S. Head of Support Functions, Norms & Learning and is a member of the Executive Committee of GFS-U.S.

The primary duties include:

  • Leading and managing a team of (~12) Compliance professionals, ensuring their professional development, and providing fair and concrete feedback and evaluations. 
  • Writing, publishing, and maintaining of the bank’s corpus of policies, procedures, and guidelines relative to sanctions compliance and associated matters. 
    • Ensuring that requirements stemming from U.S., French and European regulations are observed in the policy documents produced by GFS-U.S.
    • Ensuring that BNPP sanctions policies & procedures accurately reflect all commitments to the Bank’s auditors, regulators and supervisors. 
    • Managing consultations with GFS-US managers and other stakeholders, when writing and revising policies and procedures, and aligning with: 
      • Other Compliance Domains including GFS-Paris & KYC 
      • The Financial Security Compliance department of BNPP NY
      • Key Compliance stakeholders from the Bank’s Operational Perimeters and Regions
      • The Policies & Procedures Governance Office of central Compliance
  • Managing requests for derogations to Group Sanctions policies & procedures; following up on conditions associated with these exceptions. 
    • Evaluating and opining on Group entities’ use of non-standard IT systems in performing filtering and screening controls.
  • Advising on the interpretation of Group sanctions policies, in response to inquiries from business representatives, other compliance professionals, auditors, examiners and other stakeholders.
  • Defining the norms of the bank’s permanent control framework for Sanctions and related Financial Security and KYC controls
  • Designing and delivering the Group’s sanctions training offer in cooperation with the central Compliance Training Team; sponsoring the bank-wide certification program for compliance officers specialized in sanctions.
  • Managing Group-wide communication concerning new sanctions regimes and providing formal guidance on BNPP’s related policy and processes.
  • Organizing professional events for the bank’s business and compliance communities to promote sanctions risk awareness.
  • Co-animating, with GFS Paris & KYC, the bank-wide Sanction Compliance community; preparing and moderating the Sanctions committee.
  • Representing GFS-US in the steering of the bank’s IT strategy and projects with respect to norms for Sanctions Filtering and Screening tools.
  • Overseeing, with GFS Paris & KYC managers, the Bank’s Level A filtering activities in Lisbon and Singapore.
  • Serving as permanent secretary to the BNPP Group Financial Security Board. 
  • Represents and presents GFS-US N&L activities and projects to regulators and independent consultants.
  • Undertakes specific tasks and projects as required by the General Manager of GFS US.
  • In line with mandate or as requested by the GFS-US General Manager, represents GFS-US at steering committees, and internal and external events.
  • Develops key performance management indicators for the N&L activities and provides accurate reporting
  • Representing BNP Paribas in professional conclaves, seminars and round-tables in order to influence industry norms for sanctions compliance.

Application instructions

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