Senior Counsel, Compliance and Global Integrity
2 weeks ago
About the Role
We are looking for an experienced Senior Counsel, Global Integrity and Compliance to join our team – which is focused on enhancing and promoting Gap Inc.’s commitment to operate with integrity and on preventing, detecting and responding to unethical or illegal conduct. You will be responsible for overseeing our global Anti-Corruption Program, designing and implementing compliance risk mitigation plans, and enforcing our Code of Business Conduct (COBC), including participating in the investigation of alleged compliance concerns.
What You'll Do
- Oversee the global Anti-Corruption Program, ensure the program is updated based on developments in global laws and external trends in the marketplace, includes conducting benchmarking and keeping up to date on DOJ, SEC and other global government agencies’ expectations and guidelines.
- Assess and evolve our third-party compliance program and due diligence processes as necessary to ensure appropriate identification and mitigation of risk. Oversee the anti-corruption due diligence process. Review escalated due diligence reports for key international markets and advise colleagues and business partners on appropriate next steps.
- Ensure appropriate training of the Program is delivered to target audiences; conduct periodic review and audits of the process, including developing and implementing action plans for continuous Program improvements as necessary.
- Serve as subject matter expert on US and international anti-corruption laws, including the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, to advise the business on new or evolving initiatives and inform the COBC Program on communications and training, includes helping develop content for training or communications to target audiences, and developing policy changes related to changes in laws or best practices; also includes advising on challenges to standard anti-corruption contractual provisions, as needed.
- Demonstrated ability to understand and apply OFAC and other sanctions regulations to complex transactions, products and services. In depth understanding of OFAC's reporting requirements with an ability to manage preparation and submission of required regulatory reports. Proven experience working with senior management and influencing different stakeholders in a dynamic environment.
- Evaluate the effectiveness of and improve upon controls in place to prevent or detect unethical/illegal conduct. Prepare periodic reports on the program’s progress for the company’s Board of Directors and Chief Legal and Compliance Officer.
- Lead COBC investigations – develop investigation strategy, lead investigators, conduct interviews, as needed, and ensure proper corrective action and documentation.
- Assist with COBC Compliance Audits.
Who You Are
- JD Required; Licensed to practice law in the US with 7+ years of experience
- Proven track record of success partnering with business leaders on providing strategic guidance; Practical mindset with ability to balance legal risk with business impact
- Prior relevant work experience managing a corporate compliance program
- Experience working with international markets - Expert in anti-corruption laws, including FCPA and UK Bribery Act
- Well-versed in legal guidelines (e.g., the US Federal Sentencing Guidelines) and corporate governance best practices
- Certified compliance professional is a plus
- Franchise and privacy-related compliance experience a plus
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