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This position is responsible for supporting and providing regional analysis, program development and reporting to ensure the effective execution of the Compliance Program in the Central Europe, Middle East and Africa (CEMEA) region.

The position supports the Regional Ethics and Compliance Leader and the Regional Ethics and Compliance Officers by performing risk assessment, completing process and control testing, constructing and analyzing key metrics and compiling reports that contributes to the Compliance Program governance and oversight process. The position is key to ensuring effective risk management, decision-making and review of key processes to meet international standards and the requirements of regulations and laws of the United States as well as countries of the region. These activities include the following areas of risk:

• Anti-Bribery;
• Office of Foreign Assets Controls and other Sanctions;
• U.S. Anti-Boycott Laws;
• Anti-Money Laundering (AML) / Anti-Terrorist Financing (ATF);
• Data Privacy;
• Information Security;
• Anti-Trust and Competitive Intelligence; and

• Code of Business Conduct and Ethics;
• Conflicts of Interest; and
• Prevention of Insider Trading.

Leadership & Responsibilities

• Core Responsibilities:
  • Provide overall Ethics and Compliance Program operational support to the Regional Ethics and Compliance Officers and Regional Ethics and Compliance Leader across the CEMEA region in the areas of AML, ATF, Sanctions and Anti-Bribery
  • Complete transaction data analysis of unusual activity cases raised by the Financial Intelligence Analytics Center and co-ordinate assessment, investigations and conclusions in collaboration with the Regional AML/ATF SME and Regional Ethics and Compliance Officers
  • Review case status updates and ensure actions are maintained on the system of record
  • Review and complete AML assessment of high risk product programs, such as Visa Direct and Prepaid Card programs
  • Develop and maintain the Compliance legal and regulatory obligations library in collaboration with other stakeholders, reflecting and identifying obligations of both Visa Clients in relation to high risk regulated products operating on the Visa network, as well as obligations of Visa as a network operator
  • Develop and maintain the Country Profiles, capturing Visa’s business footprint, employee bases and legal entities, and various country and product risk assessments
  • Capture risk information including regulatory landscape changes from various internal and external sources to maintain country profiles and compile various regional and leadership governance reports
  • Capture Compliance Program risk and performance metrics from various systems and compile various regional and leadership governance reports
  • Capture data and compile a current status report on performance to the Ethics & Compliance Scorecard
  • Monitor and maintain the group e-mail account, ensuring responses to the Business are provided in a timely manner
  • Oversee and monitor scheduling and completion corporate wide, regional tailored functional group training activity, and provision of training to new hire employees
  • Design and develop tailored training materials in collaboration with Regional Ethics and Compliance Officer identified needs
  • Perform selected quality assurance testing of Ethics and Compliance Program controls and processes including intermediary status and spend documentation transactions and manage responses to the Compliance Risk Management Monitoring and testing team
  • Monitor the completion of Compliance Office Visits and client engagement program, track against the schedule and ensure maintenance of the register by the responsible Regional Ethics and Compliance Officer
  • Analyze Compliance Office Visit feedback and comprehension indicators from attendees and provide analysis and drive improvement of materials and content
  • Research allocated Compliance Program related tasks and projects, providing analysis, action plans and conclusion
  • Monitor issues captured in the Compliance Issue Management database and work with issue owners to ensure satisfactory conclusion
  • Assist in tracking and reporting of Compliance Program planning, budgeting, forecasting and expense management activities

• Collaboration & Communication:
  • Communicate openly. Develop strong and effective internal business partnerships and drive regulatory compliance matters by providing accurate and timely support to the Regional Ethics and Compliance Officer and Regional Ethics and Compliance Leader

• Enable and Inspire:
  • Ensure understanding of Visa business model, Business strategy, products, processes and controls through ongoing research and dialogue to identify potential or emerging risks and proactively raise them so as to avoid unnecessary exposure and delays to Business activity, and to ensure the Compliance Program remains effective

• Excel with Partners:
  • Respond to queries and questions on the Compliance Program, Code of Business Conduct and Ethics and company Policies from the Business, support functions, other control groups

• Act Decisively:
  • Raise identified issues and provide necessary information and analysis to enable determination of effective risk mitigation
  • Ensure responses to the Business and other Controls and Support Groups are timely, accurate and appropriate

• Risk Assessment:
  • Work with other Control Groups including Legal and Government Engagement to maintain an understanding of the legal and regulatory landscape including the support and maintenance of the legal and regulatory obligations inventory as it applies to Visa

• Control Environment:
  • Continually identify opportunities for Ethics and Compliance Program and operational process efficiencies while ensuring sufficient controls are in place; partner with the Business and other Support and Control functions to drive identified process and control improvements
  • Develop, issue and manage department operational desk instructions to provide consistency in Ethics and Compliance Program execution across the region
  • Work with Regional Ethics and Compliance Officers to implement controls related to the Visa Records Retention policies and procedures.
  • Review and analysis of pre-approval requirements for Gifts, Travel and Entertainment (GTE) requests and sponsorship events such as Olympics, FIFA and CEMEA Business Council

• Risk & Controls Reporting:
  • Develop and analyze comprehensive reporting including local dashboard of Ethics and Compliance Program activity, metrics and performance assessment

• Bachelor's degree or other higher education qualifications required

• 5+ years AML/CFT experience within financial services industry, preferably banks

• Knowledge of FATF recommendations

• Fluent English and Russian, Kazakh language skills would be an advantage

• Good knowledge of the financial services industry products, emerging products, regulations and related trends
• Good understanding of core pillars of effective AML/ATF and Sanctions programs and appropriate legislation

• Experience in compliance program operations within the financial services industry
• Experience in risk assessment, control assessment and residual risk assessment
• Advanced MS Excel skills
• Excellent process analysis and process mapping skills including use of MS Visio
• Excellent report writing, data interpretation and presentation skills
• Experience in use of SharePoint and building automated workflow management tools

• ICA Diploma in Governance, Risk & Compliance or similar qualification will be an advantage