Global Financial Crimes (GFC) coordinates day-to-day implementation of the Firm’s enterprise-wide financial crime prevention efforts. GFC includes several legal and compliance disciplines and has responsibility for governance, oversight, and execution of the Firm’s Anti-Money Laundering (AML), Sanctions, Anti-Corruption, Government and Political Activities, and Anti-Tax Evasion programs. GFC also develops and/or assists in the development of appropriate policies and procedures, including those designed to assist the business units to know their clients and conduct appropriate due diligence and to prevent, detect and report potentially suspicious activity. GFC has dedicated coverage managers and teams of analysts who advise and counsel each business unit regarding its anti-money laundering, sanctions, anti-corruption and anti-tax evasion obligations and its particular clients and transactions. The Global Anti-Tax Evasion team administers the Firm’s anti-tax evasion compliance program, which is designed to prevent the Firm and anyone acting on its behalf from engaging in activities that knowingly facilitate criminal tax evasion. The Anti-Tax Evasion Compliance Officer will report into the Global Head of Anti-Corruption, Political Activities, and Anti-Tax Evasion Compliance and will represent the anti-tax evasion compliance program in the Americas region, as well as support global strategy and processes. The role will not have any direct reports.
Provide advice and guidance to all business lines in the Americas regarding compliance with the Firm’s Global Anti-Tax Evasion Policy and related laws, rules and regulations, with a focus on Wealth Management;
Support the ongoing design, implementation, and execution of the Anti-Tax Evasion program as part of the Firm’s overall GFC framework, including:
Identify weaknesses, gaps and areas for enhancement across GFC processes and platforms that impact Anti-Tax Evasion controls, determine appropriate solutions and lead corrective action efforts
Serve as an escalation point and provide guidance with respect to Anti-Tax Evasion due diligence and risk mitigation relating to Firm clients, counterparties and transactions
Interpret and advise on relevant laws and industry best practices pertaining to Anti-Tax Evasion compliance
Identify and escalate client matters with significant reputational risk and/or potential financial crimes exposure
Provide guidance and support to GFC teams performing monitoring, testing and risk assessment activities
Create and deliver targeted Anti-Tax Evasion training
Assist in production of Anti-Tax Evasion program metrics and other management information efforts
Coordinate with technology partners to develop and/or maintain Anti-Tax Evasion systems and controls
Assist with GFC’s responses to regulatory exams and other inquiries, and internal audits, including overseeing document productions
Liaise and coordinate within GFC and with key stakeholders across the Firm with respect to execution of the Firm's Anti-Tax Evasion program, including Legal, Tax Advisory, Operations, Compliance and Risk
Represent GFC and the Global Anti-Tax Evasion team in meetings and on committees with other stakeholders; and
Participate in regional and global GFC projects and initiatives as needed.
4-year college degree with strong academic credentials
Minimum of 6 years of relevant experience, preferably at a large/complex financial institution, law firm, accounting firm, or government/regulatory body
Experience or familiarity with anti-tax evasion laws and regulations and/or laws designed to facilitate cross-border tax transparency, such as the UK Criminal Financing Act, the U.S. Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS)
Practical working knowledge of AML laws, rules, and regulations and how they are applied in a large/complex financial institution
Highly-motivated self-starter with the ability to work independently while collaborating and coordinating as part of a global program
Sound judgment and an ability to appropriately escalate issues internally
Strong verbal and written communication skills in English
Detail-oriented, flexible, and diligent
Outstanding interpersonal skills and team-player attitude
Articulate, poised, and comfortable in direct interaction with stakeholders at all levels of the organization
Proficiency with MS Outlook, Word, Excel, and PowerPoint
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