This position sits within the Compliance Anti-Bribery and Corruption team which is part of the SMBC Compliance Department Americas Division (CPAD). The Anti-Bribery and Corruption team is responsible for developing, overseeing, maintaining, and supporting the Anti-Bribery and Corruption program for the Americas Division of SMBC. The team acts in an advisory capacity and as a subject matter expert providing credible challenge to in-scope first line of defense activities and performing second level controls. This role will involve supporting the strategic development and oversight/maintenance of the Anti-Bribery & Corruption program with Manufacturer’s Bank (MB) and their digital banking unit, Jenius Bank. This role will focus on gifts and entertainment and will also support other aspects of the Anti-Bribery and Corruption program, such as third party risk review, hiring practices risk review, and donations and sponsorships risk review.

The anticipated salary range for this role is between $80,000 and $132,000. The specific salary offered to an applicant will be based on their individual qualifications, experiences, and an analysis of the current compensation paid in their geography and the market for similar roles at the time of hire. The role may also be eligible for an annual discretionary incentive award. In addition to cash compensation, SMBC offers a competitive portfolio of benefits to its employees.

• Act as an advisory to MB and Jenius Bank employees as it relates to ABC and G&E matters.
• Ensure gifts and entertainment are properly escalated and reviewed at MB. Act in an advisory capacity.
• Support the review and escalation of gifts and entertainment approval requests.
• Support the breach management process for gifts and entertainment.
• Assist with the review and maintenance of the Gifts and Entertainment and the Anti-Bribery and Corruption policies and procedures.
• Assist with maintenance, communications, and development of as well as provide training to employees for gifts and entertainment. Liaise with the Training Team in this regard.
• Assist management in remediating open audit findings and self-identified issues related to gifts and entertainment, as well as any regulatory findings.
• Assist with identifying, analyzing, monitoring, and reporting metrics related to gifts and entertainment.
• Assist with the Anti-Bribery and Corruption program where needed, including:
  • Review of proposed transactions or existing/prospective clients.
  • Reviewing and assessing escalations involving connected hires and existing employees.
  • Reviewing and assessing escalations involving charitable donations and sponsorships.
  • Assist in reviewing and assessing escalations involving third parties that may potentially pose bribery and corruption risks.
  • Assist in the maintenance of the books and records
  • Assist in the development of training
  • Assist in remediation of audits, testing, and regulatory reviews.
  • Assist in the production of anti-bribery and corruption metrics
• Support the team with multiple and simultaneous projects, liaising with other stakeholders in planning, knowledge management, and standards development.
• Coordinate and assist gathering of documents, tracking activities, and requirements associated with issue management, audit, risk assessments, and deliverables related to the gifts and entertainment and anti-bribery and corruption programs.
• Coordinate with stakeholders to ensure timely and accurate completion of deliverables.
• Develop and maintain partnerships and good working relationships with stakeholders.
• Adhere to proper departmental practices to consistently maintain and safeguard confidentiality of information and support the highest level of ethical standards.
• Identify opportunities and recommend enhancements to systems and processes
• Assist with ad-hoc projects, reviews, and other tasks and when the need arises.

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  Experience with Anti-Bribery and Corruption and/or Gifts and Entertainment related due diligence and compliance while working in a financial services firm in a Compliance, or risk and controls function with understanding of key financial services issues.
• Knowledge of the Foreign Corrupt Practices Act, UK Bribery Act, and other relevant anti-corruption laws.
• Experience in performing due diligence with third party risk review, hiring practices risk review, donations and sponsorships risk review, and gifts and entertainment.
• Experience/ Expertise in Compliance program management including but not limited to experience developing and drafting policies, procedures, communications, and training content.
• Highly analytical with effective research, professional networking, and interpersonal skills.
• Strong written and verbal communication skills and organizational skills.
• Demonstrated stakeholder managements skills, including ability to build and maintain strong relationships with a wide range of key stakeholders across business lines and functions.
• Ability to work in a dynamic environment, and adjust to changing priorities, while delivering high quality work product under strict deadlines.
• Technical proficiency in Microsoft Office (Word, Excel, Power Point, etc.).
• Self-motivated and able to handle tasks with minimal supervision.

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  Required: BA / BS / BBA (or equivalent experience)
• 3 to 5 years of comparable or relevant experience