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 these regions. 

To be successful in this role, the individual must be a qualified lawyer with extensive experience in all areas of compliance, including financial crime.  They should have exemplary communication skills and experience in designing and implementing cross-border compliance programmes.  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 financial crime compliance in the Americas, including in relation to anti-money laundering and counter terrorist and proliferation financing (AML/CTPF), sanctions and anti-bribery and corruption (ABC) and corporate offences, and will work with colleagues in the Compliance Department in relation to financial crime compliance in other regions, including EMEA & Asia;
• Assisting with developing, maintaining and keeping under review, Sotheby’s business wide risk assessments, policies and procedures in relation to financial crime, including AML/CTPF, sanctions and ABC, and in relation to corporate offences;
•  Responsible for the continuous development, improvement and implementation of Sotheby’s systems controls, policies, procedures and tools to mitigate financial crime and other risk, and partnering with Sotheby’s Service Operations, Product & Technology and Information Security teams on the same;  
• Act 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 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; and overseeing enhanced due diligence and recommendations to local senior management on approval of client onboarding or transactions;
• Oversight of regulatory affairs in the Americas, including for example, FCA related matters, acceptance of crypto-currencies and sale of non-fungible tokens (NFTs), and advising on and managing related policies, procedures and escalations;Supporting with any reporting or filing requirements that fall within the remit of the Compliance department, and on any regulator audit or risk assessment or other relevant government or regulator engagement;
•  Maintaining in-depth knowledge of relevant financial crime and corporate offence regulations, laws 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 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;
• Assisting with maintaining Sotheby’s Code of Business Conduct and non-financial crime compliance policies and procedures (including, for example, anti-trust and conflicts of interest) to ensure that the company and its employees have sufficient information and guidance to allow them to comply with applicable laws and regulations and company-wide policies and ethical standards;
• Providing accurate and timely advice and guidance to Sotheby’s staff on issues arising from compliance policy areas and