Attorney
Axiom Law
Total years of experience :13 years, 5 Months
• Current client engagement at Micron Technology. Previous clients include TechnipFMC, AFLAC, Deutsche Bank and Allergan.
Client: Micron Technology
• Support the global trade team at a semiconductor company, by developing and implementing human rights, ethics and forced labor due diligence policies and processes to align with both U.S. and non-U.S. regulations; serve as an escalation contact for resolving both internal and external compliance issues; provide guidance and advice regarding import/export issues to peers and upper-level management, while assuring full compliance with all applicable laws and regulations.
• Draft and issue detailed internal reports to senior stakeholders that include an analysis of enhanced diligence findings, an assessment of risks and recommended corrective action regarding Company’s supply chain partners in China.
• Provide legal guidance to the human resources team on the relevance of "deemed" exports in the Company's recruitment process; research, analyze, and provide legal guidance on the requirements of the CHIPS Act relating to counterfeit goods.
Client: TechnipFMC
• Support the global trade team of an oil and gas services firm by applying in-depth knowledge of sanctions/trade laws and regulations to complex cases, often involving OFAC, UK and EU sanctions regulations across various jurisdictions such as China, Russia and other high-risk jurisdictions; disposition sanctions screening alerts and lead the implementation of automated sanctions screening, along with remediating accounts/relationships; successfully lead system tuning efforts that significantly reduce the number of false positives and other inefficiencies; develop a comprehensive embargo/sanctions compliance program, including the drafting of program and business-level policies/procedures and training of personnel; integrate global trade requirements across jurisdictions and monitor compliance with import/export and sanctions regulations.
• Refine Company’s third-party due diligence program, including streamlining review workflows that ultimately increased sanctions review efficiencies through implementation of a formal, business-wide process review of Company’s trade portfolio; support the restructuring of the compliance and sanctions functions across several businesses and defined responsibilities for 30+ employees that subsequently increased efficiencies and capabilities of Company personnel.
• Perform ongoing, manual reviews of new and existing relationships that includes screening of counterparties against sanctions lists, interpreting screening results, performing comprehensive due diligence on new and existing relationships and recommending appropriate risk mitigation solutions; avoid regulatory actions and penalties as a direct result of my efforts.
• Manage incoming communications from internal and external stakeholders, including drafting communications to obtain relevant information as part of the due diligence process; coordinate any necessary follow-up; coordinate with IT to implement system blocks to ensure Company is not doing business with prohibited business partners.
• Recommend risk mitigation measures tailored to the case at hand; execute sound judgment in deciding whether a case is within the Company’s risk tolerance.
• Advise the wealth and asset management business on AML/Sanctions matters, assist with regulatory reporting, and assess business compliance with AML/Sanctions requirements by performing risk assessments and quality assurance testing; collaborate with the business teams to operationalize compliance requirements tailored for wealth management product/ service offerings; liaise with senior management across all three ‘lines of defense’, including business functions for remediation projects.
• Create and implement an AML/Sanctions regulatory framework and through these efforts, client-facing personnel are empowered to draft business-specific AML and sanctions operational procedures achieving compliance with AML program requirements as well as satisfying commitments to regulators.
• Perform customer and enhanced due diligence on new and existing relationships; responsible for ensuring the implementation of system blocks for prohibited accounts/activities; conduct suspicious activity monitoring, investigations through internal and external resources, dispositioning system-generated, compliance alerts and actioning on internal, self-disclosures.
• Develop and lead ongoing training of personnel on anti-money laundering and sanctions concepts; refine internal third-party due diligence processes, including streamlining workflows and updating AML/Sanctions policies and procedures.
• Support the wealth and asset management business by spearheading the implementation of business unit AML and Sanctions Programs to prevent illegal, unethical, or improper business practices; assist in the execution and oversight of activities to comply with the Bank Secrecy Act, USA PATRIOT ACT and Sanctions Program requirements; ensure that compliance and front office manuals, corporate policies, and procedures accurately reflect current laws and other internal/external requirements.
• Perform routine AML/Sanctions risk assessments for the Company’s wealth management portfolio, key components of which include spot-audits and evaluating risk factors (e.g. customer type, geography, offerings); communicate findings, in oral and written form, to senior stakeholders and oversee the implementation of appropriate risk mitigation measures; identify improvement opportunities and recommend corrective action to mitigate AML/Sanctions risks; oversee the implementation of corrective measures, and perform follow-ups as needed.
• Vet technology vendors and select compliance management systems and software; create a third-party due diligence program to manage relationships with global manufacturers and distributors based in high-risk jurisdictions across Asia; negotiate terms and conditions of purchase orders; responsible for the submission of insurance claims for any damaged merchandise.
• Assist with the processing of work visas for corporate clients in the MENA region.
• Conduct legal research on Islamic law, publish articles in law journals, and assist with the launch of a Sharia law blog.
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