Vice President/Director, Global Financial Crime Manager (Japan Sanctions)

Bank of America

Bank of America

Accounting & Finance
Tokyo, Japan · United States · Remote
Posted on Monday, April 29, 2024

Job Description:

At Bank of America, we are guided by a common purpose to help make financial lives better through the power of every connection. Responsible Growth is how we run our company and how we deliver for our clients, teammates, communities and shareholders every day.

One of the keys to driving Responsible Growth is being a great place to work for our teammates around the world. We’re devoted to being a diverse and inclusive workplace for everyone. We hire individuals with a broad range of backgrounds and experiences and invest heavily in our teammates and their families by offering competitive benefits to support their physical, emotional, and financial well-being.

Bank of America believes both in the importance of working together and offering flexibility to our employees. We use a multi-faceted approach for flexibility, depending on the various roles in our organization.

Working at Bank of America will give you a great career with opportunities to learn, grow and make an impact, along with the power to make a difference. Join us!

Job Description:

The GFC Japan Sanctions Manager, is responsible for executing substantive economic sanctions compliance and operational risk practices related to providing direction in Japan in any Sanctions related matters requiring input and for assisting Global Economic Sanctions (GES) executives with the Risk Assessment program in alignment with the GFC Enterprise Policy, Standard, and Risk Assessment Methodology.

The GFC Japan Sanctions Manager will establish and maintain strong relationships with key stakeholders within the Front Line Units (FLUs) and Control Functions (CFs), GFC risk executives and managers, and internal audit using effective influence skills; interaction with local and international regulators is also within this role execution.


  • Apply knowledge of sanctions regulations to support the Financial Crimes Program in Japan on any sanctions related matters requiring input.
  • Review and decision transactions for potential sanctions issues and perform research on transactions stopped on the firm's sanctions screening systems, as required. Monitor the changes in sanctions regulations, including advising business leaders, directing the appropriate areas to implement or amend policies, standards, procedures and/or processes to address regulatory requirements, and challenging the implementation plan as needed.
  • Participate in sanction industry forums and monitors regulatory expectations, emerging legislation and regulation, political scrutiny, litigation, and key influencers to identify and mitigate emerging risks.
  • Supervise or execute, as applicable, the submission of Japan Sanctions-related regulatory reports.
  • Provide expert advice and counsel to FLUs/CFs in Sanctions related matters (transactions, product development, etc.)
  • Responsible for undertaking targeted risk assessments from a Sanctions standpoint for Japan and more broadly.
  • Leverage available data and analytical tools during the planning, execution, and oversight of the sanctions risk assessment process.
  • Develop subject matter expertise of sanctions risks and a solid business understanding of application of these risks within a large financial institution.
  • Deliver sanctions training initiatives to enhance sanctions knowledge and skills in the Japan branch.
  • Oversight of sanctions operations partners including key metrics and sample reviews as required.
  • Undertake sanctions gap assessments as and where required.
  • Advises and direct the development and maintenance of local GFC-owned Sanctions related procedures, training and other required documentation, and reviews relevant FLUs/CF-owned policies and standards to ensure that sanctions regulatory requirements and existing risks are appropriately addressed.
  • Produce and/or oversee independent sanctions risk management reporting.
  • Escalate sanctions related compliance and operational risks and issues to appropriate governance routines, management/board level committees.
  • Challenge the remediation and thematic analysis of FLU/CF-owned issues and control enhancements related to sanctions.
  • Assist in preparing materials for sanctions related regulatory exams/audits/inquiries and may assist with preparation for FLU/CF sanction regulatory exams/audit deliverables.
  • Support the wider GES team and GES Execs on other sanctions matters as and when required.

Required Skills:

  • The successful candid will have prior experience in supporting a financial crimes program in Japan from a Sanctions standpoint and experience in risk management or audit, as well as a good understanding of 2nd line coverage activities inclusive of risk assessments, monitoring, testing and/or quality assurance processes.
  • Significant experience of 7+ years and knowledge of Financial Crimes / Japanese Economic Sanctions program requirements and their application to Global Banking and Markets businesses;
  • Must be deeply familiar with regulations, best practices and tools and associated Sanctions local regulatory reporting.
  • Knowledge of US OFAC is expected and understanding of any other sanctions regulations would also be valuable.
  • Experience understanding payments.
  • Experience and interest in drafting targeted risk assessments for countries, legal booking entities (not client level risk assessments) and products.
  • Solid understanding of the Japanese financial sector and any experience in regulatory interactions is valuable.
  • Ability to synthesize laws, rules, and regulations into practice to provide clear and straightforward guidance.
  • Sound risk management based on advanced analytical skills, critical thinking supported by facts and metrics available and an ability to apply discernment, take decisions when required and to escalate concerns when necessary. Exceeding verbal and written communication skills.
  • Be comfortable with fast paced decision making and with working with multiple international stakeholders, and cross-group collaboration.

Desired Skills

  • Experience in technology implementation projects including involvement in building new or enhancing existing systems to meet complex reporting requirements
  • Professional Qualifications (Accountancy Qualifications)