Sr. Manager - Global Financial Crimes Testing

Global Compliance and Ethics (GCE) is responsible for establishing and maintaining a robust compliance program that ensures American Express is adhering to laws, regulations, and internal policies while fostering a culture of integrity and effective second line independent Compliance oversight.

We are seeking an experienced and proactive professional to join our Compliance team as a Senior Manager in International Independent Compliance Testing (ICT). The successful candidate will take ownership of substantial review areas or workstreams, coordinate day-to-day testing delivery, quality-assure Analysts’ work, develop evidence-based conclusions, and manage working-level stakeholder engagement. This role requires strong technical and analytical capability, sound judgement, developing leadership skills, and the ability to operate effectively in a complex, global regulatory environment.

This role is focused on Financial Crime Compliance and requires strong subject matter expertise in Anti-Money Laundering (AML), Economic Sanctions, Know Your Customer/Customer Due Diligence (KYC/CDD), Anti-Bribery and Corruption (ABC), Financial Crimes Investigations, Transaction Monitoring, and Suspicious Activity Reporting.

The successful candidate will leverage this expertise to independently assess the design and effectiveness of financial crime controls, challenge management assumptions, identify emerging risks, and evaluate compliance with global regulatory requirements and internal standards across multiple jurisdictions.

Review Leadership & Delivery

• Manage substantial elements of assigned ICT reviews from planning through fieldwork and reporting, in accordance with ICT methodology, internal standards, and the direction set by the review lead.
• Develop review scope, testing approaches, work programs, and delivery plans, taking ownership of defined risk areas or workstreams.
• Coordinate day-to-day delivery across assigned review areas, allocate testing activity, monitor progress, and escalate quality or delivery risks.
• Review testing documentation and workpapers to confirm that procedures are complete, evidence is sufficient, and conclusions are clear and supportable.
• Monitor and assess regulatory developments, enforcement actions, and industry guidance related to AML, sanctions, KYC/CDD, ABC, and broader financial crime compliance risks, incorporating impacts into testing approaches and review coverage.
• Maintain a strong understanding of global financial crime regulations and expectations, including applicable requirements relating to anti-money laundering, sanctions compliance, customer due diligence, suspicious activity reporting, anti-corruption, and beneficial ownership.
• Use review experience and data-led insights to improve testing efficiency, consistency, and quality.

Risk Identification, Assessment & Reporting

• Provide independent and objective assessment of financial crime compliance risks and control effectiveness through testing and analysis.
• Identify, assess, and clearly articulate potential issues or findings, applying professional skepticism and sound judgement.
• Challenge the quality and sufficiency of evidence, root-cause analysis, impact articulation, and proposed corrective actions.
• Draft concise, evidence-based review reports and governance materials, escalating significant concerns promptly.
• Support consistent issue classification and reporting across reviews.

Stakeholder Engagement & Influence

• Build a strong understanding of relevant business models, products, services, processes, and regulatory obligations.
• Partner with Legal Entity Compliance Officers, business teams, second line risk functions, General Counsel, and Internal Audit to align scope, obtain evidence, and minimize unnecessary duplication.
• Lead working-level and management stakeholder engagement for assigned reviews, driving discussions related to scope, progress, emerging risks, findings, and remediation activities, and providing timely escalation of significant concerns.
• Provide credible challenge and influence stakeholders to address identified risks and control weaknesses.
• Communicate complex testing matters clearly to management and governance audiences.

Team Leadership & Development

• Lead, coach, and quality-assure the work of Analysts and other review team members, including colleagues across locations.
• Set clear expectations for assigned testing activity, provide timely feedback, and support professional development.
• Promote consistent application of ICT methodology and share technical knowledge and lessons learned.
• Contribute to an inclusive, collaborative, accountable, and continuous-learning culture.
• Support resource planning, workload management, and capability development across the team.

Framework & Regulatory Alignment

• Apply and champion the global ICT framework, standards, procedures, and templates.
• Contribute practical review insights to enhancements of testing methodology, tools, templates, and reporting.
• Monitor regulatory and industry developments relevant to assigned jurisdictions or risk areas and assess implications for testing.
• Support alignment of review plans and execution with local regulatory requirements, risk profiles, business priorities, and evolving regulatory expectations.

Minimum Qualifications:

• Minimum 5+ years of experience in Financial Crime Compliance, Compliance Testing, Internal Audit, Risk Management, Regulatory Compliance, or related assurance functions within financial services.
• Strong subject matter expertise in AML, Sanctions, KYC/CDD, ABC, Transaction Monitoring, Financial Crime Investigations, and Suspicious Activity Reporting.
• Experience designing, executing, or overseeing independent testing, compliance reviews, audits, or assurance activities covering financial crime compliance programs and controls.
• Strong understanding of global financial crime regulations and regulatory expectations, including familiarity with FinCEN, OFAC, FATF, FCA, EU AML Directives, and other applicable regulatory frameworks.
• Experience assessing control frameworks and regulatory requirements across multiple jurisdictions and legal entities.
• Strong working knowledge of compliance testing methodologies, control assessment techniques, root cause analysis, issue management, and risk management principles.
• Ability to independently challenge management assumptions, evaluate risk-based decisions, and form evidence-based conclusions regarding the effectiveness of financial crime controls.
• Experience managing review workstreams and quality-assuring the work of others.
• Strong analytical, interviewing, stakeholder management, and report-writing skills.
• Experience coaching and developing team members while supporting high-quality review delivery.
• Ability to manage competing priorities and operate effectively in a fast-paced, matrixed, global organization.
• Proficiency in Microsoft Excel, Word, and PowerPoint.

Preferred Qualifications:

• Experience using data analytics and technology-enabled testing techniques preferred.
• ACAMS (Certified Anti-Money Laundering Specialist), ICA Financial Crime certification, Certified Global Sanctions Specialist (CGSS), or equivalent financial crime certification strongly preferred.

Employment eligibility to work with American Express in the United States is required as the company will not pursue visa sponsorship for these positions.