Compliance Officer

THE ROLE

Based in New York and reporting to the Compliance Counsel, the position is responsible for the continued implementation and delivery of Sotheby’s group-wide legal regulatory and ethical compliance program worldwide with responsibility for managing all aspects of global compliance across Sotheby’s locations (Americas, UK, EMEA and Asia).

Sotheby’s Global Compliance & Business Integrity department oversees the design and implementation of a mature and in-depth compliance program, covering not only the full range of traditional compliance subject matters (ranging from AML/CTF compliance, sanctions, trade compliance, anti-corruption, competition/anti-trust, data protection/privacy and information security) but through to subject matter expertise pertinent to the art market (such as legal movement of works of art, export/import regulation, cultural heritage, regulations governing live and online auctions, private sales and introductory commissions).

The Compliance Officer will ensure that Sotheby’s and its employees are aware of and in compliance with applicable laws, regulations and ethical standards; providing legal compliance advice to business groups worldwide on compliance-related matters affecting Sotheby’s business.

RESPONSIBILITIES

• Implement Sotheby’s Code of Business Conduct, policies, procedures, manuals and internal codes that have been adopted by the Company, to ensure that Sotheby’s and its employees are at all times in compliance with applicable laws, regulations and company-wide policy and ethical standards, which relate to any of Sotheby’s existing Compliance policies.
• Maintain a comprehensive understanding of the legal and regulatory environment, requirements and developments relating to and impacting Sotheby’s business activities worldwide. Monitor and maintain accurate and up to date knowledge of, and updating policies as needed, concerning subject matter areas under the responsibility of the Global Compliance department, which include:
  • The transparent and fair conduct of auctions and private sales;
  • Due diligence relating to property and clients;
  • Anti-money laundering and government sanctions;
  • Anti-bribery and corruption (such as the FCPA, UK Bribery Act);
  • Antitrust;
  • Conflicts of interest;
  • Cultural property/heritage matters;
  • Endangered species;
  • Data protection and information privacy
  • Information security
• Develop, maintain and deliver an education and training program to inform employees on legal, regulatory and ethical matters that exist or may evolve and come under the responsibility of the Compliance Department, and to update relevant staff on any relevant changes.
• Provide timely and accurate advice and guidance to Sotheby’s staff on issues arising from compliance policy areas and subject matter within the responsibility of the Compliance Department.
• Design and implement procedures, including internal audits, in order to detect at the earliest time possible any violations of Sotheby’s policies or legal, regulatory or ethical requirements, including the conduct of internal investigations as required to address any questionable incidents or practices.
• Provide guidance and oversight of compliance to monitor the efficacy of the Compliance program, detect issues, violations and areas for improvement relating to policies or legal, regulatory or ethical requirements. This includes, where appropriate, directing and performing Compliance audits.
• Monitor legislative and regulatory developments and participate in industry lobbying efforts impacting the market.

IDEAL EXPERIENCE & COMPETENCIES

• 5-8 years of demonstrable in-house experience in compliance and ethics program
• Qualified attorney with a background in regulatory practice a plus
• Understanding of traditional financial crime compliance legal subject matter, such as
• anti-money laundering, sanctions, anti-bribery and corruption and related best practice;
• Experience in data protection/data privacy advantageous
• Art market experience highly desirable, in particular, experience and knowledge of cultural
• heritage laws and international treaties worldwide; auction market regulations;
• Strong commercial acumen
• An enthusiastic and dynamic disposition. The role requires a collaborative approach with a
• proactive and ‘can do’ mindset to operate in Sotheby’s global matrix organization. Excited to
• deal with the unexpected coupled with a self-starter approach, strong work ethic and the
• ability to multi-task, prioritize and follow through on multiple matters simultaneously.
• Demonstrable experience of working autonomously
• Excellent communication skills (written and verbal), other languages desirable
• Ability to manage a variety of internal clients and build relationships to advance the strategic
• objectives of the Compliance team.
• Exceptional organization, planning, and time management skills.

The proposed base salary for this position ranges from $125,000-$160,000. In addition to base salary successful candidates are eligible to receive a discretionary bonus, as well as a competitive benefits package. Salary offers are based on a wide range of factors including relevant skills, training, experience, education, and, where applicable, licensure or certifications obtained. Market and organizational factors are also considered.