Senior Counsel, Sanctions & AML

<div class="content-intro"><p><a href="https://www.sofi.com/sofi-employee-applicant-privacy-notice/" target="_blank"><strong>Employee Applicant Privacy Notice</strong></a></p> <p><strong>Who we are:</strong></p> <div> <p>Shape a brighter financial future with us.</p> <p>Together with our members, we’re changing the way people think about and interact with personal finance.</p> <p>We’re a next-generation financial services company and national bank using innovative, mobile-first technology to help our millions of members reach their goals. The industry is going through an unprecedented transformation, and we’re at the forefront. We’re proud to come to work every day knowing that what we do has a direct impact on people’s lives, with our core values guiding us every step of the way. <strong>Join us to invest in yourself, your career, and the financial world.</strong></p> </div></div><p><span style="color:#000000"><b>The role:</b></span><br><br><span style="color:#000000">SoFi is looking for a Senior Counsel with deep experience in economic sanctions and anti-money laundering (AML) to join the Legal team. This attorney will be the company's go-to legal expert on U.S. sanctions administered by the Office of Foreign Assets Control (OFAC). They will also advise on Bank Secrecy Act (BSA) and AML requirements across SoFi's products and lines of business. The role works closely with Compliance, the BSA/AML Officer, Risk, Product, Engineering, Operations, and Financial Crimes teams. It also supports regulatory examinations and engagement with federal banking regulators and OFAC.</span><br><br><span style="color:#000000"><b>What you'll do:</b></span></p><ul><li><span style="color:#000000">Act as the lead legal advisor on OFAC sanctions programs, including country-based and list-based sanctions, the 50 Percent Rule, sectoral sanctions, and secondary sanctions risk.</span></li><li><span style="color:#000000">Advise on how sanctions screening, blocking, rejecting, and reporting obligations work in practice. This includes blocked property reports, rejected transaction reports, and annual reports of blocked property.</span></li><li><span style="color:#000000">Assess possible sanctions violations. Lead internal investigations and advise on voluntary self-disclosures to OFAC under the Economic Sanctions Enforcement Guidelines.</span></li><li><span style="color:#000000">Prepare and submit specific license requests, interpretive guidance requests, and other correspondence to OFAC. Advise on how general licenses apply.</span></li><li><span style="color:#000000">Advise on BSA/AML requirements, including customer due diligence (CDD), beneficial ownership, Customer Identification Program (CIP), suspicious activity reporting (SAR), currency transaction reporting (CTR), recordkeeping, and FinCEN requirements.</span></li><li><span style="color:#000000">Review and advise on SoFi's sanctions and AML policies, procedures, risk assessments, and screening methods. Partner with Compliance to keep the program effective and in line with regulatory expectations.</span></li><li><span style="color:#000000">Give legal guidance on new products, features, partnerships, and markets, such as payments, cross-border activity, digital assets, and fintech partnerships. Identify sanctions and AML risks and practical ways to reduce them.</span></li><li><span style="color:#000000">Support regulatory examinations, inquiries, and enforcement matters with the OCC, Federal Reserve, FinCEN, OFAC, and other agencies.</span></li><li><span style="color:#000000">Review and negotiate sanctions and AML provisions in vendor, partner, and commercial agreements.</span></li><li><span style="color:#000000">Track legislative, regulatory, and enforcement developments, including new sanctions designations, AML Act rulemakings, and enforcement trends. Explain their impact clearly to business stakeholders and senior leaders.</span></li><li><span style="color:#000000">Create and deliver training on sanctions and AML legal requirements for internal teams.</span></li><li><span style="color:#000000">Manage outside counsel on sanctions and AML matters.</span></li></ul><br><p><span style="color:#000000"><b>What you'll need:</b></span></p><ul><li><span style="color:#000000">J.D. from an ABA-accredited law school, with active membership in good standing in at least one U.S. state bar.</span></li><li><span style="color:#000000">7 to 10 years of legal experience, with substantial and direct focus on U.S. economic sanctions (OFAC) and BSA/AML regulation.</span></li><li><span style="color:#000000">Specific, demonstrated OFAC expertise, including:</span></li></ul><ul><li><span style="color:#000000">In-depth knowledge of OFAC regulations (31 C.F.R. Chapter V), sanctions programs, and enforcement practice.</span></li><li><span style="color:#000000">Hands-on experience preparing license applications, voluntary self-disclosures, and responses to OFAC subpoenas or administrative inquiries.</span></li><li><span style="color:#000000">Experience advising on screening, blocking and rejecting decisions, and sanctions compliance program design consistent with OFAC's <i>A Framework for OFAC Compliance Commitments</i>.</span></li></ul><ul><li><span style="color:#000000">Strong working knowledge of the BSA, the USA PATRIOT Act, the Anti-Money Laundering Act of 2020, and FinCEN regulations.</span></li><li><span style="color:#000000">Experience advising banks, broker-dealers, money services businesses, fintech companies, or other regulated financial institutions.</span></li><li><span style="color:#000000">Excellent judgment, with the ability to turn complex legal requirements into clear, practical, risk-based advice for non-lawyers.</span></li><li><span style="color:#000000">Strong written and oral communication skills, including experience presenting to senior leaders.</span></li><li><span style="color:#000000">Ability to work independently and handle several priorities in a fast-paced environment.</span></li></ul><br><p><span style="color:#000000"><b>Preferred qualifications:</b></span></p><ul><li><span style="color:#000000">Prior work at OFAC (for example, in the Office of Compliance and Enforcement, Licensing Division, Office of the Chief Counsel (Foreign Assets Control), or a sanctions policy role), or at the U.S. Department of the Treasury in a sanctions-focused role. <b>Strongly preferred.</b></span></li><li><span style="color:#000000">Experience in the sanctions, AML, or financial regulatory practice of a leading law firm, <b>or </b>previous in-house experience at a bank, fintech, or other regulated financial services company. Candidates who combine OFAC government service with law firm or in-house experience are especially encouraged to apply.</span></li><li><span style="color:#000000">Experience with digital assets, payments, or cross-border transaction sanctions issues.</span></li><li><span style="color:#000000">Experience with the export control laws (EAR) and their overlap with sanctions compliance.</span></li><li><span style="color:#000000">Familiarity with sanctions screening technology, transaction monitoring systems, and vendor management.</span></li><li><span style="color:#000000">Experience supporting regulatory examinations by federal banking regulators.</span></li></ul><div class="content-conclusion"><div class="gmail_default"><strong>Compensation and Benefits</strong></div> <div class="gmail_default">The base pay range for this role is listed below. Final base pay offer will be determined based on individual factors such as the candidate’s experience, skills, and location. </div> <div class="gmail_default"> </div> <div class="gmail_default">To view all of our comprehensive and competitive benefits, visit our <strong><a href="https://sofietyinfo.sofi.com/sofi-benefits" target="_blank" data-saferedirecturl="https://www.google.com/url?q=https://sofietyinfo.sofi.com/sofi-benefits&source=gmail&ust=1667318410571000&usg=AOvVaw0ZqbRtznVe1JsWWUOWQUnN">Benefits at SoFi</a> </strong>page!</div> <h5 style="text-align: center;"><span style="font-weight: 400;">SoFi provides equal employment opportunities (EEO) to all employees and applicants for employment