The candidate will conduct a legal review of due diligence records for Covered Business Partners (“CBP”) operating throughout the world (currently over 1,000 in total). Review compiled CBP responses and supporting documentation - identify red flags and risks to the company that may exist in any proposed third-party relationship. Analyze potential adverse information identified in media searches and denied party screening process. Review and analyze local law summaries pertinent to any third-party CBP agreement to ensure that the proposed relationship would comply with applicable laws. Review and analyze outside counsel opinions concerning any investigations involving the CBP. Assess Business Unit rationale, proposed compensation and other factors in connection with the requested CBP review. Coordinate with Business Unit Legal Counsel regarding questions, red flags and other potential issues that may be raised during CBP due diligence to assess risk, identify follow-up actions or recommendations for mitigating GACC risk to the Business Unit. Develop guidance and provide Corporate Officer with an overview of due diligence and recommendations concerning requests from Business Units to appoint or retain a CBP, or requests to amend existing CBP agreements. Serve as a subject matter and legal resource for GACC Policy related questions, including but not limited to questions and issues involving due diligence for third party Business Partners, transactions with government customers, gifts, hospitality, entertainment and travel for government officials and others, charitable contributions outside of the U.S. and GACC training needs; and provide guidance to Business Units concerning the CBP review process. Develop and draft updates, revisions and clarifications to GACC Policy, Supplement, supporting exhibits and procedures. GACC risk assessments and providing support to Business Units to implement new processes required for compliance with GACC Policy. Implement new procedures or protocols and providing training to Business Units as needed. Identify and analyze changes to the U.S. and foreign anti-bribery laws (“Global Anti-Corruption Laws”) or guidance concerning Global Anti-Corruption Laws, and determining impact to policies, practices and procedures. Review all non-U.S. charitable contribution requests from Business Units in accordance with requirements set forth in the GACC Policy, identify any GACC related red-flags or issues and provide recommendations to Compliance Counsel as to whether they should be approved. Provide support, as needed, for anti-corruption investigations. Provide support for the process for monitoring gift and entertainment expenses, including providing a legal review, as needed. Provide support and guidance to Business Units concerning the Freight Forwarder Protocol. Develop and deliver training to Business Units on GACC and other compliance-related topics, and supporting training of Business Units’ CBPs. Protect and maintain the privacy of employee personnel records including, but not limited to, personal and compensation information about employees. Open to future career development opportunities within Business Unit locations. Other duties, as assigned
Qualification and Experience
The candidate should have a Law degree from an accredited institution. Admission in good standing to a State Bar. Corporate or law firm experience on compliance matters, such as Foreign Corrupt Practices Act (FCPA), preferred. Strong analytical, investigatory and research skills. Good problem-solving and decision-making abilities. Excellent written and oral communication skills. Strong interpersonal skills. Strong work ethic. Keen customer-service focus. Strong organizational skills—Ability to prioritize tasks based on relative importance and urgency. High integrity is required.
JOB ID: GACC-295990.
40 westminster Street
Providence, RI 02903