Compliance Director - Anti-Money Laundering - Fidelity Investments - Boston

Job description
This individual will serve in Fidelity’s enterprise-wide Anti-Money Laundering Office (“AMLO”) as a subject matter expert in, anti-money laundering (“AML”) compliance under the Bank Secrecy Act of 1970, as amended by the USA PATRIOT Act of 2001 and other laws, and related regulations (collectively, the “BSA”) and foreign AML laws and regulations, as necessary. AMLO is an organ of Fidelity’s parent company that oversees global AML compliance by business units and central support groups (collectively, referred to as “Business Units”) on behalf of entities that are “financial institutions,” as defined in the BSA, that include (or will shortly include):
Broker-dealers, including a clearing broker-dealer with hundreds of introducing relationships
A federal savings bank
Trust companies
Families of mutual funds with separate Boards, hundreds of underlying funds, and thousands of intermediaries
Insurance companies
A money services business
Registered investment advisers

Primary Responsibilities
Issue AML regulatory guidance and policy decisions to Business Units and other relevant stakeholders. The Anti-Money Laundering Compliance Director (“AML Director”) is responsible for providing guidance to all applicable Business Units and other relevant stakeholders across Fidelity concerning specific sets of AML requirements and making routine policy decisions for the Business Units. The objectives of the guidance are (i) to prevent regulatory violations, (ii) to interpret applicable regulations and how they address the firm’s business model, (iii) to ensure adequate consideration of all relevant suspicious activity risks and vulnerabilities, (iv) to ensure consistency of interpretation of equivalent regulations in multiple business contexts across the complex, and (v) to share experiences and recommendations concerning operational compliance challenges.
Perform regulatory oversight of Business Units’ implementation efforts for new AML rules, AML compliance efforts, and new products or services. The AML Director may be assigned specific compliance systems or process implementation efforts. The roles and responsibilities of the AML Director may include (i) reviewing and approving implementation plans to ensure that they adequately address applicable laws, regulations, AMLO interpretations, and/or independent testing or examination findings, (ii) addressing regulatory questions and issues arising on the critical path to implementation, (iii) tracking progress and escalating any delivery delays or failures for resolution. Implementation oversight requires that the AML Director coordinate closely with business sponsors and project managers.
Coordinate responses to AML regulator requests. When regulators examine a Fidelity financial institution, and the examination includes AML compliance, an AML Director is assigned to oversee the response . The duties may include: (i) providing AMLO documentation responsive to requests, (ii) reviewing and providing comments on responses and responsive documentation provided by Business Unit contacts, as appropriate, (iii) drafting written responses, explanations and other responsive material, as necessary, and (v) performing any necessary research and analysis.
Review, revise and approve Business Unit AML compliance policies and procedures, training, forms, etc., as required.
Address high-risk situations. When customers engage in high-risk suspicious activity, the AML Director analyzes applicable regulatory requirements and facts gathered by Business Unit Risk, Compliance or other relevant stakeholders to develop recommended responses.
Draft AMLO program documentation, including the AML Compliance Policy and Procedure (CPP”) that AMLO maintains.
Perform central oversight of Business Units’ AML practices. The AML Director is assigned routine tasks of reviewing and validating the results of Business Unit analyses and processes, including the supervision, monitoring and oversight (“SMO”) controls in place for each element of the BSA/AML regulations as noted on the SMO matrix.
Present on AML topics in various meetings, including the Fidelity AML Committee.
Key Interactions
Business Units. Routinely vice presidents, directors, risk managers, other senior compliance advisors and project managers; occasionally senior vice presidents
Regulators. Various U.S. Treasury officials at Financial Crimes Enforcement Network (“FinCEN”). Examiners from the Securities and Exchange Commission (“SEC”), Financial Industry Regulatory Authority (“FINRA”), Office of the Comptroller of the Currency (“OCC”), Massachusetts, New Hampshire, etc.
Legal. Associate and assistant general counsels, outside counsel, when appropriate.
Internal and External Audit.
Counterparts at other firms.
Customer Protection and Financial Intelligence Group personnel.

Desired Skills and Experience
Education and Experience

Each AML Director must have, at a minimum, an undergraduate degree and at least one of the following:
Significant relevant experience in AML compliance implementation or operations in the financial services industry
At least five years of relevant experience as a financial services risk, compliance or legal professional
Significant relevant regulatory or enforcement experience at a financial services regulatory agency
At least five years of relevant Fidelity experience
A J.D., M.B.A. or Masters degree in international affairs is strongly preferred
Skills and Knowledge

The AML Director must have:
An understanding of securities brokerage business
Familiarity with asset management business
Excellent written and oral communication skills, including the ability to communicate clearly, concisely and effectively in varied levels of detail and through varied media to a wide range of critical audiences
Ability to drive multiple, competing, complex initiatives to completion simultaneously
demonstrated ability to build pleasant and effective working relationships in complex organizations
Proven analytical skills, including ability to master complex and large volumes of data and to interpret regulatory requirements subtly, carefully, creatively, and prudently
Outstanding advocacy and influencing skills

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