Associate General Counsel, Compliance, Americas

ABOUT SOTHEBY'S

Established in 1744, Sotheby’s is the world’s premier destination for art and luxury. Sotheby’s promotes access to and ownership of exceptional art and luxury objects through auctions and buy-now channels including private sales, e-commerce and retail. Our trusted global marketplace is supported by an industry-leading technology platform and a network of specialists spanning 40 countries and 70 categories which include Contemporary Art, Modern and Impressionist Art, Old Masters, Chinese Works of Art, Jewelry, Watches, Wine and Spirits, and Design, as well as collectible cars and real estate. Sotheby’s believes in the transformative power of art and culture and is committed to making our industries more inclusive, sustainable and collaborative.

THE ROLE

This role will be based in New York reporting to the Chief Compliance Officer and Deputy General Counsel, Global Head of Litigation and will assist with developing, implementing and managing all aspects of compliance in the Americas, including providing advice to business groups and senior stakeholders on compliance related matters affecting Sotheby’s business in this region.

To be successful in this role, the individual must be a qualified attorney with extensive experience in all areas of compliance, particularly in relation to financial and trade sanctions, white collar crime and anti-trust.  They should have exemplary communication skills and experience in designing and implementing cross-border compliance programs, and also with engaging with federal and state agencies and regulators.  They will also have the ability to build strong relationships with our business clients and senior stakeholders, and to give considered and practical advice on complex matters.  The right person for this role will be a self-starter who has sufficient expertise and experience in this area to be able to operate autonomously. 

RESPONSIBILITIES

• Responsible for compliance in the Americas, including in relation to anti-money laundering and counter terrorist and proliferation financing (AML/CTPF), anti-bribery and corruption (ABC) and other white-collar crime, financial and trade sanctions, anti-trust, conflicts of interest, due diligence on clients and property, cultural property / heritage, endangered species, and working alongside and collaboratively with colleagues in the Compliance Department in other regions;
• Assisting with the continuous development, improvement and implementation of Sotheby’s Code of Business Conduct, business-wide risk assessment, policies, procedures, and systems controls and tools to mitigate risk, and partnering with colleagues in Sotheby’s Legal and Compliance Department, and Service Operations, Product & Technology and Data Privacy / Information Security teams on the same;
• Acting as point of escalation to advise on and assist with the onboarding of new clients and review of existing clients and their transactions, including regarding collection and review of KYC and client due diligence documents and screening results; resolution of screening results through automated tools (primarily, LSEG Worldcheck); review of existing client due diligence documents and ongoing screening; review and investigation of high-risk clients and transactions; overseeing enhanced due diligence and recommendations to local senior management on approval of client onboarding or transactions;
• Acting as a point of escalation to advise on and assist with all other areas which fall within the remit of the Compliance Department, including property due diligence, and import and export, cultural property and heritage, and endangered species policy areas;
• Oversight of regulatory affairs in the Americas, including in relation to acceptance of crypto-currencies and sale of non-fungible tokens (NFTs), and advising on and managing related policies, procedures and escalations; and supporting with any reporting or filing requirements that fall within the remit of the Compliance department, and assisting with engaging with any federal or state agencies, law enforcement or regulators (including, for example, State Attorneys (AGs), OFAC, DOJ, Fish & Wildlife, FBI, DHS, FinCen) and in relation to contentious regulatory or litigation matters in the region;
• Maintaining in-depth and up to date knowledge of relevant federal, state and local law, regulations and regimes, and updating relevant staff on any relevant changes and best practices;
• Assisting with developing, maintaining, and delivering an education and training programme to inform employees on financial crime, anti-trust and other legal, regulatory and ethical matters that exist or which are likely to become relevant and which fall withing the remit of the Compliance Department, and maintenance of training records for the same;
• Providing accurate and timely advice and guidance to Sotheby’s staff on issues arising from compliance policy areas and subject matters within the responsibility of the Compliance Department;
• Assisting with designing and implementing procedures to monitor and audit the efficacy of the Compliance program, detect issues, violations and areas for improvement relating to policies or legal, regulatory or ethical requirements;
• Supporting senior stakeholders on larger projects by providing assistance and advice in connection with compliance related aspects;
• Taking an active role in knowledge sharing, thought leadership and practice development to ensure Sotheby’s remains abreast of developments in or updates to federal, state and local laws, regulations and practices in relation to financial crime, antitrust and other matters falling within the remit of the Compliance Department; and
• Ensuring appropriate record retention and management.

IDEAL EXPERIENCE & COMPETENCIES

• Bachelor’s Degree and JD (must have State Bar admission in New York);
• 8+ years of professional experience at a large or boutique law firm with extensive experience in regulatory and financial crime practice areas; 3+ years of government or in-house experience is a plus;
• Experience of advising on white collar crime or of financial crime compliance is a must, particularly in relation to financial and trade sanctions, ABC (FCP), AML/CTPF, and experience of engaging with federal and state agencies and regulators (for example, State Attorneys (AGs), OFAC, DOJ, Fish & Wildlife, FBI, DHS, FinCen);
• The ideal candidate will have previous experience with legal, regulatory and / or corporate compliance, and of developing, implementing and managing cross-border compliance programs;
• Proficiency and experience in using relevant screening tools (for example, LSEG Worldcheck, Dow Jones, Lexis Nexis);
• Experience in transaction monitoring, in particular of block chain transactions, and fraud detection;
• Excellent analytical and written skills are vital, able to produce clear, high-quality writing; advanced communication and presenting skills are also important;
• Ability to assess and balance commercial and regulatory risks, to think strategically and to clearly and concisely provide advice, often in time pressured circumstances;
• Ability to provide clear guidance and workable, commercial solutions on complex and sensitive issues;
• Excellent relationship management and people skills, team player mentality with the ability to work alongside colleagues, and with clients, their representatives and other stakeholders;
• Maintaining excellent stakeholder management and communication skills with the ability to bring all stakeholders on board;
• Professional and calm manner; able to multi-task and prioritize and capable of working independently across the Americas, and accommodating of other time zones when necessary;
• Additional language skills helpful; and
• Art law / art industry experience is not a strict requirement but helpful to the extent it brings with it experience and knowledge of cultural heritage, import / export and endangered species laws and other regulations, laws and regimes relevant to the art market and conduction of auctions.

The proposed base salary for this position ranges from $175,000-$200,000. In addition to base salary successful candidates are eligible to receive a discretionary bonus, as well as a competitive benefits package. Salary offers are based on a wide range of factors including relevant skills, training, experience, education, and, where applicable, licensure or certifications obtained. Market and organizational factors are also considered. 

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The Company is an equal opportunity employer and considers all applicants for employment without regard to race (including, without limitation, traits historically associated with race, such as natural hair, hair texture, and protective and treated or untreated hairstyles), color, creed, religion, sex, sexual orientation, marital or civil partnership/union status, national origin, age, disability, pregnancy, genetic predisposition, genetic information, reproductive health decision, sexual orientation, gender identity or expression, alienage or citizenship status, domestic violence victim status, military or veteran status, or any other characteristic protected by federal, state/province or local law. The Company complies with applicable state and local laws prohibiting discrimination in employment in every jurisdiction in which it operates.