Director, AML Policy & Program Oversight

  • Company: PayPal
  • Location: San Jose, California
  • Posted: December 22, 2017
  • Reference ID: R0026331
Job Description
Fueled by a fundamental belief that having access to financial services creates opportunity, PayPal (NASDAQ: PYPL) is committed to democratizing financial services and empowering people and businesses to join and thrive in the global economy. Our open digital payments platform gives PayPal's 210 million active account holders the confidence to connect and transact in new and powerful ways, whether they are online, on a mobile device, in an app, or in person. Through a combination of technological innovation and strategic partnerships, PayPal creates better ways to manage and move money, and offers choice and flexibility when sending payments, paying or getting paid. Available in more than 200 markets around the world, the PayPal platform, including Braintree, Venmo and Xoom enables consumers and merchants to receive money in more than 100 currencies, withdraw funds in 56 currencies and hold balances in their PayPal accounts in 25 currencies.

This position reports to the Sr. Director, Enterprise Risk, Compliance, and Security (ERCS) Head of Global AML. In this position, you be responsible for AML Policy advisory, guidance and direction to business units, operational support areas, and product areas that are critical to the effectiveness of PayPal's global program around financial crime compliance. This role is responsible for cataloging and aligning global and regional AML Policies and then ensuring these policies and related standards are updated and maintained in accordance with regulatory requirements globally. In addition, this role is responsible for evaluating and defining ways to enhance Policy and Standards to optimize on efficiency while still meeting PayPal's regulatory expectations globally.
This role will also be responsible for oversight of exams and audits by external parties, which includes various U.S. Federal and State Regulators, global regulatory bodies, and PayPal Internal Audits globally. You will be responsible for developing a program to support the external and internal exam processes, ensure robust documentation is available to respond to inquiries and appropriately maintained, interface with internal and external groups in support of the exam processes and oversee outcomes, including resulting issues and tracking of resolution plans.
You will work in close collaboration with multiple areas of the company in multiple regions across PayPal's footprint, which require excellent communication and collaboration. This role will also be responsible for overseeing subject matter for training courses and will be leading a small team.

Responsibilities include:

● Coordinate the review and update global AML guidelines, standards, policies and other governance documentation
● Stay apprised of AML regulatory changes globally to assist in determining PayPal impacts and drive program changes
● Provide clear and succinct communication both verbally and in writing to all levels of management and staff
● Oversee exams and audits by external and internal parties, which includes various U.S. Federal and State Regulators, global regulatory bodies, and PayPal Internal Audits globally.
● Develop a program to support the external and internal exam processes that includes a method to document and maintain materials supporting the AML program components while ensuring information provided is responsive to the inquiry and reflective of the area under review.
○ Collaborating with regional teams to ensure programmatic process to support requests generated for regional regulatory exams and internal audits.
● Ensure robust documentation is available to respond to inquiries and appropriately maintained, interface with internal and external groups in support of the exam processes and oversee outcomes, including leading the process to oversee identified issues and tracking of resolution plans and related remediation actions.
○ Overseeing maintenance of materials prepared and provided in response to exams, to ensure robust tracking of documentation provided and to facilitate leveraging prior materials for future requests and maintaining consistency across internal and external exams.
○ Drive timely delivery of requests, including coordinating across GFCC and, when necessary, ERCS Leadership to achieve any appropriate engagement, review and approvals.
● Key liaison between AML functions and the larger Audit, Examinations and Regulatory Relations team.
● Overseeing global AML training courses to ensure alignment with policy, legal requirements and practices.
● Actively developing relationships and working collaboratively with cross functional groups and leaders within and outside of PayPal to drive for results and influence issue resolution.
● Championing the goals and objectives of ERCS across the organization.

  • The ideal candidate will have senior GFCC experience within a large, complex financial services institution and is adept at navigating a complex and continuously changing global regulatory ecosystem.
  • The successful candidate will hold a minimum 10 years of AML, Compliance, law enforcement or similar experience. A college degree and relevant experience in a senior position at a large financial institution is preferred.
  • Extensive technical knowledge of U.S. and International AML and Sanctions regulations, and a detailed understanding of the Bank Secrecy Act (BSA), USA Patriot Act and OFAC (Foreign Asset Control Regulations).
  • Technologically conversant with a knowledge of Analytics, Data Science and Big Data is considered to be enormously advantageous.
  • Must possess exceptional interpersonal and influencing skills, with the ability to partner effectively at multiple levels and across disciplines.
  • Exceptional project management skills, with the demonstrated ability to build and manage the day-to-day operations of large, complex GFCC programs in a changing regulatory environment.
  • Proven ability to operate in ambiguous environments and exhibit agility in navigating from current state to proposed solutions.

We're a purpose-driven company whose beliefs are the foundation for how we conduct business every day. We hold ourselves to our One Team Behaviors which demand that we hold the highest ethical standards, to empower an open and diverse workplace, and strive to treat everyone who is touched by our business with dignity and respect. Our employees challenge the status quo, ask questions, and find solutions. We want to break down barriers to financial empowerment. Join us as we change the way the world defines financial freedom.

PayPal provides equal employment opportunity (EEO) to all persons regardless of age, color, national origin, citizenship status, physical or mental disability, race, religion, creed, gender, sex, pregnancy, sexual orientation, gender identity and/or expression, genetic information, marital status, status with regard to public assistance, veteran status, or any other characteristic protected by federal, state or local law. In addition, PayPal will provide reasonable accommodations for qualified individuals with disabilities.


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