Senior Counsel - Sanctions & AML

The role:

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

What you'll do:

• Act as the 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 how sanctions screening, blocking, rejecting, and reporting obligations work in practice. This includes blocked property reports, rejected transaction reports, and annual reports of blocked property.
• Assess possible 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 how general licenses apply.
• Advise on BSA/AML requirements, including customer due diligence (CDD), beneficial ownership, Customer Identification Program (CIP), suspicious activity reporting (SAR), currency transaction reporting (CTR), recordkeeping, and FinCEN requirements.
• Review and advise on SoFi's sanctions and AML policies, procedures, risk assessments, and screening methods. Partner with Compliance to keep the program effective and in line with regulatory expectations.
• Give legal guidance on new products, features, partnerships, and markets, such as payments, cross-border activity, digital assets, and fintech partnerships. Identify sanctions and AML risks and practical ways to reduce them.
• Support regulatory examinations, inquiries, and enforcement matters with the OCC, Federal Reserve, FinCEN, OFAC, and other agencies.
• Review and negotiate sanctions and AML provisions in vendor, partner, and commercial agreements.
• Track legislative, regulatory, and enforcement developments, including new sanctions designations, AML Act rulemakings, and enforcement trends. Explain their impact clearly 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.

What you'll need:

• J.D. from an ABA-accredited law school, with 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.
• Specific, demonstrated OFAC expertise, including:

• 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 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, with the ability to turn 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 handle several priorities in a fast-paced environment.

Preferred qualifications:

• Prior work at OFAC (for example, in the Office of Compliance and Enforcement, Licensing Division, Office of the Chief Counsel (Foreign Assets Control), or a sanctions policy role), or at the U.S. Department of the Treasury in a sanctions-focused role. 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. Candidates who combine OFAC government service with law firm or in-house experience are especially encouraged to apply.
• Experience with digital assets, payments, or cross-border transaction sanctions issues.
• Experience with the 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.

Pay Range: $198,400.00 - $341,000.00
Pay Transparency Range: 198400.0 - 341000.0 USD