Risk & Compliance Counsel and AML Officer

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Title :

Risk & Compliance Counsel and AML Officer

Location :

Frankfurt

Job Summary

Gibson Dunn is a leading global law firm, advising clients on significant transactions and disputes. Our exceptional teams craft and deploy creative legal strategies that are meticulously tailored to every matter, however complex or high-stakes. The firm’s work is distinguished by a unique combination of precision and vision.

Based in Frankfurt or Munich, the primary responsibilities of the Risk and Compliance Counsel and AML Officer, Germany (hereinafter, “German R&C Counsel and AMLO”) will be to support the Firm’s German Offices by fulfilling the role of the Firm’s Anti-Money Laundering (AML) Officer for its German offices, with the responsibilities as set forth in § 7 of the German Act against Money Laundering (Gesetz über das Aufspüren von Gewinnen aus schweren Straftaten vom 23.06.2017, BGBl. I S. 1822 – Geldwäschegesetz – “GwG”) and in the Firm’s AML and Counter Terrorist Financing (CTF) Procedures for its German offices.

Secondarily, the German R&C Counsel and AMLO will supervise and manage a Compliance Specialist located in one of the Firm’s German offices, foster a risk and compliance-aware culture in the Firm’s German offices by engaging with Firm partners and other colleagues regarding regulatory requirements and expectations, and work with the Firm’s global Compliance Officer, global Compliance Manager, and stakeholders to streamline and improve AML and other compliance-related processes.

Thirdly, the German R&C Counsel and AMLO will serve as the appointed professional law representative (“Berufsrechtsbeauftragter”) within the meaning of § 31 of the Professional Code of Conduct for Lawyers (“BORA”). In this capacity, the German R&C Counsel and AMLO shall assist the Firm’s German Offices with the obligations of attorneys practicing in these offices to duly fulfill their obligations under the applicable German, and the Firm’s, ethical and compliance rules and standards.

This role will report to the Firm’s global Compliance Officer, with indirect (i.e., dotted line) reporting into the Partners in Charge of the Firm’s German Offices.

Responsibilities include:

AML focused:

  • Ensuring that the onboarding of new clients and matters complies with the GwG and the Firm’s internal AML/CTF, client due diligence (CDD), and screening policies for trade sanctions, politically exposed persons (PEPs), adverse media, etc.
  • Providing AML/CTF legal and regulatory interpretation and advice in the context of prospective new client and new matter intake, especially in relation to clients and matters identified to carry enhanced risk, and, if possible, with respect to trade sanctions / export control laws and policies.
  • Leading the Firm’s Germany office Compliance team (currently one AML Coordinator, soon to be replaced with a Compliance Specialist), in coordination with the Firm’s global Compliance Officer and global Compliance Manager, and working collaboratively with other departments to integrate compliance management into business processes; further training and upskilling the Germany Compliance team members and promoting that team’s adherence to the Firm’s internal processes, developed by or in coordination with the Firm’s global Compliance Officer and global Compliance Manager.
  • Fostering a risk and compliance-aware culture in the Firm’s German offices, engaging with Firm partners and other colleagues regarding AML/CTF/CDD and other legal and regulatory requirements and expectations in Germany, and working with stakeholders to streamline processes; engaging with regulators and clients as needed or requested.
  • Leading on monitoring for developments and changes with respect to German AML/CTF rules and regulations and regulatory requirements and expectations; providing timely updates on such developments and changes to key stakeholders; coordinating with the global Compliance Officer and Partners in Charge of the Firm’s German offices, as applicable, with updating/implementing applicable policies and procedures.
  • Overseeing the Firm’s German office compliance monitoring efforts, including identifying and addressing any compliance concerns, and making recommendations to key stakeholders on any areas requiring attention.
  • Updating, developing, and, in coordination with the Germany Compliance team, delivering training for new and existing attorneys and relevant staff on the client intake processes, with particular focus on CDD and AML/CTF processes and procedures and regulatory requirements and expectations.
  • Overseeing and coordinating the preparation of responses to German AML/CTF questionnaires and German bar audits as and when requested or required by local regulators, and leading on the preparation of the German offices’ AML/CTF risk assessments.
  • Responding to internal suspicious activity reports or other referrals and ensure they are quickly assessed and documented, including (where appropriate) reporting to the relevant authorities.
  • Participating in planning discussions with respect to, and assisting with, testing and/or piloting of new third-party or internally constructed software applications relating to client intake, AML/CTF compliance, CDD, trade sanctions and export control compliance, client lifecycle management, and other compliance initiatives more generally.

Risk & Compliance focused relating to BORA and Ethical Standards:

  • Overseeing the Firm’s German office compliance monitoring efforts flowing from obligations under the BORA and the related measures initiated under § 31 BORA, including identifying and addressing any compliance concerns, and making recommendations to the Firm’s global Compliance Officer and the Partners in Charge of the Firm’s German Offices on any areas requiring attention.
  • Overseeing and coordinating the preparation of the German Offices’ annual risk analysis with regard to the risk of violations of relevant obligations under the Professional Code of Conduct and Ethical Standards (Berufsrecht).
  • Overseeing the Firm’s German office risk mitigation and compliance monitoring efforts with regard to attorneys’ obligations under the applicable Professional Code of Conduct and Ethical Standards, including identifying and addressing any compliance concerns, and making recommendations to key stakeholders on any areas requiring attention.

Qualifications

  • Proven track record of managing a team successfully and developing colleagues.
  • Ability to work independently and strategically, while also being a team player; strong leadership and team management skills.
  • Ability to identify, resolve, and communicate regarding issues concisely and in a timely and effective manner.
  • Ability to organize and prioritize multiple assignments in a fast-paced environment; work under pressure and complete job assignments in an accurate and timely manner; respond appropriately to shifting demands.
  • Strong research, analytical, and problem-solving skills with attention to detail; experience with analyzing data, with advanced Excel skills a plus.
  • Excellent written and oral communication in German and English, excellent interpersonal skills and, ability to interact effectively with a broad range of colleagues in a professional manner.

Experience

  • Minimum of three (3) years of experience working either at a senior level within a global law firm, an accounting firm, or another professional services firm on German AML/CTF and, ideally, sanctions compliance (as an AML Officer or with direct reporting into an AML Officer or Deputy AML Officer preferable), or for a German bar authority in a law firm audit or similar capacity.
  • German trained (Rechtsanwalt, Diplomjurist, Wirtschaftsjurist) who is experienced in AML/CTF (and ideally sanctions).
  • Strong understanding and working knowledge of legal, ethical, and regulatory obligations for lawyers in Germany, including the GwG.

 

Gibson Dunn will consider for employment qualified Applicants with Criminal Histories in a manner consistent with the requirements of local law.

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Gibson Dunn & Crutcher LLP is committed to the principles of equal employment opportunity for all partners, employees and applicants and, in accordance with the applicable federal and state laws, does not discriminate on the basis of sex, race, creed, color, religion, matriculation or political affiliation, national origin, alienage or citizenship status, ancestry, age, marital status or partnership status, family responsibilities, disability, medical condition, personal appearance, genetic information, predisposing genetic characteristics, sexual orientation, military status, status as a victim of domestic violence, stalking and sex offenses, arrest or conviction record, or on any other basis prohibited by law.