Sanctions Compliance Manager
The Sanctions Compliance Manager is responsible for overseeing and ensuring an organization's compliance with sanctions, trade regulations, and laws set forth by OFAC and other international sanction programs. This positions plays a critical role in safeguarding the organization against legal and financial risks associated with non-compliance to sanctions and trade regulations by being responsible for the daily operations of the bank-wide Sanctions screening process. This role is expected to be the subject matter expert regarding sanctions concerns and the central point of contact for sanctions related matters. Additionally, this role is responsible for required regulatory reporting.
Position Responsibilities:
Sanctions Compliance
- Develop and implement policies and procedures to ensure compliance with U.S and global regulations and sanctions programs that align to the enterprise sanctions framework.
- Set the sanctions policy and establish risk-based procedures to prevent, detect, and report potential sanctions violations.
- Monitor and analyze new sanctions and trade restrictions issued by OFAC and other global regulatory bodies.
- Collaborate with other departments on implementation of any new or changed, laws, rules, regulations, and products or services.
- Review and ensure compliance with applicable sanctions and appropriate disclosures on marketing collateral, and customer-facing documents.
- Conduct risk assessments to identify potential violations or high-risk areas and recommend mitigation strategies.
- Partner with Line of Business, Compliance, Risk and third parties to ensure that all processes and procedures are following applicable policies and regulations.
- Manages periodic audits of automated OFAC systems to ensure sanction screening processes are compliant with regulatory expectations.
Screening & Due Diligence
- Oversee the screening of customers, transactions, and counterparties against U.S and global sanction lists and other restricted entities.
- Ensure that proper due diligence is conducted for high-risk clients or transactions; and that the organization is not conducting business with prohibited individuals, entities, or countries.
- Conduct Politically Exposed Person (PEP) Reviews.
Reporting & Documentation
- Oversee the preparation and submission of reports to regulatory authorities as required, including reports of blocked transactions, or rejected payment.
- Prepare and submit Suspicious Activity Reporting (SAR) to report activity from reviewed sanction alerts, politically exposed person reviews or international cases involving sanctionable parties.
- Conducts Audits, Tests and Monitors Activity.
Leadership
- Advisor to the first line of defense on transactions and customers with potential sanctions-related risks.
- Point of contact for OFAC, managing day-to-day communication and coordination.
- Serve as the subject matter expert and provides training and awareness programs for employees on OFAC regulations, sanctions lists, and internal policies on both the first and second line of defense.
- Stay updated on regulatory changes and disseminate relevant information to the organization.
- Lead a team of sanctions analysts responsible for performing second-level reviews of sanctions hits, providing guidance, support, and direction as needed.
Position Qualifications:
- Bachelor's Degree from an accredited university or 4 years of relevant experience OR a High School Diploma or GED and 6 years of Risk Management or other related experience in the Financial Services Industry
- 6 years of banking or financial services experience
- 4 years of experience leading OFAC regulatory processing functions
- 3 years of Federal Banking Regulation (Bank Secrecy Act/USA PATRIOT Act) experience
Preferred Qualifications:
- Experience managing or leading a team
Licenses & Certifications:
About Comerica
We know our employees are critical to our overall success and we are dedicated to investing in their future. One of the ways we do this is to offer a comprehensive Total Rewards package designed to recognize and reward individual performance, as well support health, well-being, development and security for our colleagues and their family. Total Rewards consists of cash compensation, development and flexible benefit programs designed to meet individual needs today and in the future. Your salary will be commensurate with your work experience and our programs are reviewed regularly to ensure each remain competitive. We are proud to offer benefits such as health and welfare programs, strong retirement benefits, and generous paid time off programs. You and your eligible family members, including domestic partners and their children, can participate in medical, dental, and vision benefits, 401(k) and pension, income protection benefits such as life insurance, AD&D, and supplemental health programs to offset unexpected health care expenses. We also have a variety of time off programs for things like vacation, sick time, disability, and parental leave. Eligibility for some programs varies based on employment status and tenure.
Upon offer, Comerica conducts a comprehensive background and fingerprint check. Your fingerprints will be used to check the criminal history records of the FBI and may be subscribed in the FBI's Record of Arrest and Prosecution Background ("RAP Back") service, which provides ongoing notification to the Company of any updates to your criminal history.
NMLS certification requirement: where applicable, a favorable background check screening, credit check, fingerprint check, and NMLS certification is required in accordance with the SAFE Act.
Comerica Incorporated (NYSE: CMA) is a financial services company headquartered in Dallas, Texas, and strategically aligned into three major business segments; the Commercial Bank, the Retail Bank, and Wealth Management. Comerica's colleagues focus on relationships, and helping people and businesses be successful. In addition to Texas, Comerica Bank locations can be found in Arizona, California, Florida and Michigan, with select businesses operating in several other states, as well as in Canada and Mexico.
Comerica is proud to be an Equal Opportunity Employer - veterans/individuals with disabilities, committed to workplace diversity.
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Comerica Bank
life insurance, parental leave, paid time off, sick time, 401(k)
May 17, 2025