Senior Counsel, Sanctions & AML

Overview

This role involves serving as the go-to legal expert on U.S. economic sanctions administered by the Office of Foreign Assets Control (OFAC), with additional advisory responsibility for Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements across products and lines of business.

The position 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.

Responsibilities

• Act as lead legal advisor on OFAC sanctions programs, including:
  • Country-based and list-based sanctions
  • The 50 Percent Rule
  • Sectoral sanctions
  • Secondary sanctions risk
• Advise on how sanctions screening, blocking, rejecting, and reporting obligations work in practice, including:
  • Blocked property reports
  • Rejected transaction reports
  • 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 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 sanctions and AML policies, procedures, risk assessments, and screening methods; partner with Compliance to keep the program effective and aligned with regulatory expectations
• Provide legal guidance on new products, features, partnerships, and markets (including payments, cross-border activity, digital assets, and fintech partnerships); identify sanctions and AML risks and practical risk-reduction approaches
• Support regulatory examinations, inquiries, and enforcement matters with:
  • OCC
  • Federal Reserve
  • FinCEN
  • OFAC
  • 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; clearly explain impacts 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

Requirements

• J.D. from an ABA-accredited law school
• 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)
  • BSA/AML regulation

Specific, demonstrated OFAC expertise

• In-depth knowledge of OFAC regulations (31 C.F.R. Chapter V), sanctions programs, and enforcement practice
• Hands-on experience preparing license applications and voluntary self-disclosures, and responding 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

Additional requirements

• 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 and ability to translate 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 manage multiple priorities in a fast-paced environment

Preferred Qualifications

• Prior work at OFAC (e.g., 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
• Experience in sanctions, AML, or financial regulatory practice at a leading law firm, or in-house experience at a bank, fintech, or other regulated financial services company; candidates combining OFAC government service with law firm or in-house experience are especially encouraged
• Experience with digital assets, payments, or cross-border transaction sanctions issues
• Experience with 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 & 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 comprehensive and competitive benefits, refer to the organization’s Benefits page.

The organization provides equal employment opportunities (EEO) to all employees and applicants for employment without regard to protected characteristics under applicable state or federal law.

In accordance with the San Francisco Fair Chance Ordinance, qualified applicants with arrest and conviction records will be considered.

Location

• Reasonable accommodations are available for candidates with physical or mental disabilities; if accommodations are needed to participate in the application or interview process, notify the recruiter.
• Remote work cannot be accommodated from Hawaii, Alaska, or Puerto Rico at this time.

Additional Notes

• Internal employees: If you are a current employee, do not apply through this posting.
• New York applicants: Notice of Employee Rights.