Senior Manager, Compliance

Senior Manager, Anti-Bribery, Anti-Corruption, Anti-Money Laundering And Sanctions Compliance

At CVS Health, we're building a world of health around every consumer and surrounding ourselves with dedicated colleagues who are passionate about transforming health care.

As the nation's leading health solutions company, we reach millions of Americans through our local presence, digital channels and more than 300,000 purpose-driven colleagues caring for people where, when and how they choose in a way that is uniquely more connected, more convenient and more compassionate. And we do it all with heart, each and every day.

Position Summary

We are seeking a Senior Manager experienced with anti-bribery, anti-corruption (ABAC), anti-money laundering (AML) and sanctions compliance to include those regulations published by Department of Treasury's Office of Foreign Assets Control (OFAC) as well as other key regulatory bodies in jurisdictions where the Company does business. This role will develop and design standard processes and associated policies and procedures for Aetna International due diligence. In this role, you will ensure our organization meets complex regulatory requirements related to financial crimes, international business practices and ethical operations especially where healthcare intersects with global partnerships, claims processing, third-party relationships and government affiliated entities. The successful candidate will have a strong background in healthcare compliance and deep understanding of the unique regulatory landscape impacting the insurance environment.

Lead responsibilities will include working across business lines for Aetna International and other key departments. Applicants should have an understanding of insurance industry and third-party relationships as well as associated risks and leading processes / controls related to third-party due diligence and screening. Foreign Corrupt Practices Act (FCPA), UK Bribery Act, AML and OFAC compliance are core knowledge areas. Attention to detail and metrics analysis are a must as this role will oversee an annual risk assessment and audit process.

This role will be part of the CVS Health Anti-Money Laundering and Financial Crimes Compliance team. As part of this colleague's core function, this colleague will align the policies of these programs with Aetna International's evolving business practices. This includes monitoring and screening individuals, providers, claims payments and business partners against Politically Exposed Persons (PEP) lists, OFAC lists and other global sanctions lists where the Company does business.

Collaborate with leaders from Aetna International, Commercial, Government, Business Compliance Office (BCO), Legal, Network Team and Claims Processing Team to standardize due diligence process for international third-party relationships. This includes tailoring the AML, financial crimes and sanctions programs to health insurance company services and associated risks.

Provide oversight of internal or external audits where Aetna International compliance due diligence, AML or sanctions compliance processes are impacted for example those audits related to Canada lines of business or information requested by the Office of the Superintendent of Financial Institutions (OSFI) / Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). Implement enhancements resulting from audit findings as needed. Communicate status updates with Senior Leadership.

Lead annual risk assessment for anti-bribery / FCPA, AML and sanctions for Aetna International. Identify risks and create a risk assessment process with data analysis and key observations. Provide oversight for implementation of all recommendations based on risk assessment observations. Report results to Senior Leadership.

Formalize FCPA expectations especially in relation to government affiliated providers and payors. Examine current processes and enhance efforts where needed. Develop policies and procedures to reflect processes. Implement relevant control recommendations within Aetna's Sales Force.

In order to be successful in this role you must exhibit the following :

• Understanding of anti-money laundering, financial crimes compliance, and anti-corruption concepts.
• Familiarity with Office of Foreign Assets Control (OFAC), Financial Action Task Force (FAFT) and other key regulatory bodies.
• Experience communicating with internal and external auditors.
• Experience simplifying complex data and concepts based on different audiences.

Required Qualifications

Preferred Qualifications

Education

Bachelor's degree required or equivalent years of related experience.

Pay Range

The typical pay range for this role is :

$75,400.00 - $182,549.00

This pay range represents the base hourly rate or base annual full-time salary for all positions in the job grade within which this position falls. The actual base salary offer will depend on a variety of factors including experience, education, geography and other relevant factors. This position is eligible for a CVS Health bonus, commission or short-term incentive program in addition to the base pay range listed above. This position also includes an award target in the company's equity award program.

Our people fuel our future. Our teams reflect the customers, patients, members and communities we serve and we are committed to fostering a workplace where every colleague feels valued and that they belong.

Great benefits for great people

We take pride in our comprehensive and competitive mix of pay and benefits investing in the physical, emotional and financial wellness of our colleagues and their families to help them be the healthiest they can be. In addition to our competitive wages, our great benefits include :

Affordable medical plan options, a 401(k) plan (including matching company contributions), and an employee stock purchase plan.

No-cost programs for all colleagues including wellness screenings, tobacco cessation and weight management programs, confidential counseling and financial coaching.

Benefit solutions that address the different needs and preferences of our colleagues including paid time off, flexible work schedules, family leave, dependent care resources, colleague assistance programs, tuition assistance, retiree medical access and many other benefits depending on eligibility.

Qualified applicants with arrest or conviction records will be considered for employment in accordance with all federal, state and local laws.