Senior Counsel, Sanctions & AML

SoFi•New York, NY
•$198,400 - $341,000

About The Position

SoFi is seeking a Senior Counsel with substantial experience in U.S. economic sanctions and anti-money laundering (AML) to join its Legal team. The attorney will serve as the company's primary legal expert on sanctions administered by the Office of Foreign Assets Control (OFAC) and advise on Bank Secrecy Act (BSA) and AML requirements across SoFi's products and business lines. The role partners with Compliance, the BSA/AML Officer, Risk, Product, Engineering, Operations, and Financial Crimes teams, and supports regulatory examinations and engagement with federal banking regulators and OFAC.

Requirements

  • J.D. from an ABA-accredited law school.
  • Active membership in good standing in at least one U.S. state bar.
  • 7 to 10 years of legal experience, with substantial and direct focus on U.S. economic sanctions (OFAC) and BSA/AML regulation.
  • In-depth knowledge of OFAC regulations (31 C.F.R. Chapter V), sanctions programs, and enforcement practice.
  • Hands-on experience preparing license applications, voluntary self-disclosures, and responses to OFAC subpoenas or administrative inquiries.
  • Experience advising on screening, blocking, and rejecting decisions, and on sanctions compliance program design consistent with OFAC's A Framework for OFAC Compliance Commitments.
  • Strong working knowledge of the BSA, the USA PATRIOT Act, the Anti-Money Laundering Act of 2020, and FinCEN regulations.
  • Experience advising banks, broker-dealers, money services businesses, fintech companies, or other regulated financial institutions.
  • Excellent judgment and ability to translate complex legal requirements into clear, practical, risk-based advice for non-lawyers.
  • Strong written and oral communication skills, including experience presenting to senior leaders.
  • Ability to work independently and manage several priorities in a fast-paced environment.

Nice To Haves

  • Prior work at OFAC, such as in the Office of Compliance and Enforcement, Licensing Division, Office of the Chief Counsel (Foreign Assets Control), or a sanctions policy role, or in a sanctions-focused role at the U.S. Department of the Treasury; strongly preferred.
  • Experience in the sanctions, AML, or financial regulatory practice of a leading law firm, or previous in-house experience at a bank, fintech, or other regulated financial services company.
  • Combined OFAC government service and law firm or in-house experience.
  • Experience with digital assets, payments, or cross-border transaction sanctions issues.
  • Experience with export control laws (EAR) and their overlap with sanctions compliance.
  • Familiarity with sanctions screening technology, transaction monitoring systems, and vendor management.
  • Experience supporting regulatory examinations by federal banking regulators.

Responsibilities

  • Serve as lead legal advisor on OFAC sanctions programs, including country-based and list-based sanctions, the 50 Percent Rule, sectoral sanctions, and secondary sanctions risk.
  • Advise on sanctions screening, blocking, rejecting, and reporting obligations, including blocked property reports, rejected transaction reports, and annual reports of blocked property.
  • Assess potential sanctions violations, lead internal investigations, and advise on voluntary self-disclosures to OFAC under the Economic Sanctions Enforcement Guidelines.
  • Prepare and submit specific license requests, interpretive guidance requests, and other correspondence to OFAC; advise on the application of general licenses.
  • Advise on BSA/AML requirements, including customer due diligence, beneficial ownership, Customer Identification Program, suspicious activity reporting, currency transaction reporting, recordkeeping, and FinCEN requirements.
  • Review and advise on sanctions and AML policies, procedures, risk assessments, and screening methods, partnering with Compliance to maintain an effective program aligned with regulatory expectations.
  • Provide legal guidance on new products, features, partnerships, and markets, including payments, cross-border activity, digital assets, and fintech partnerships; identify and help mitigate sanctions and AML risks.
  • Support regulatory examinations, inquiries, and enforcement matters involving the OCC, Federal Reserve, FinCEN, OFAC, and other agencies.
  • Review and negotiate sanctions and AML provisions in vendor, partner, and commercial agreements.
  • Monitor legislative, regulatory, and enforcement developments, including sanctions designations, AML Act rulemakings, and enforcement trends, and explain their impact to business stakeholders and senior leaders.
  • Create and deliver training on sanctions and AML legal requirements for internal teams.
  • Manage outside counsel on sanctions and AML matters.
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