Sanctions Policy, Governance and Change Manager - Global Payment

Responsibilities

About the Team
The Global Payment team provides TikTok payment solutions, including payment acquisition, disbursements, transaction monitoring, payment method management, foreign exchange conversion, accounting, and reconciliations, ensuring a smooth and secure payment experience on the TikTok platform. The Global Payment Compliance team leverages industry and technological expertise to provide compliance policy, oversight, advisory, and operational support across our company's products and services.

About the Role
We are seeking a strategic Compliance Lead to own the Global Sanctions Program framework. This role serves as the guardian of the Sanctions Policy, ensuring alignment with evolving global regulations (OFAC, UK HMT, EU, UN, etc.). You will drive governance over program health and manage regulatory and business-driven changes, including new product launches.

Responsibilities

Sanctions policy development and maintenance
- Develop, update, and maintain sanctions policies, standards, and procedures across product lines (payments, onboarding, KYC/IDV, ad services, developer APIs, and social features) aligned with OFAC, U.S., E.U., UK, and MAS requirements. Own the annual review of the Global Sanctions Policy and related standards.
- Translate regulatory developments (e.g., Executive Orders, EU Regulations) into actionable internal requirements and training materials for product, operations, and customer-facing teams.
- Maintain a sanctions playbook covering ownership, escalation paths, governance, and product lifecycle integration.
- Partner with regional compliance teams to adapt global policies to local requirements without diluting global standards.
- Conduct regular gap analyses to ensure policy design effectiveness aligns with operational execution.

Governance and oversight
- Define and implement a global sanctions governance structure with clear roles, responsibilities, and accountability.
- Collaborate with Compliance Advisory, Legal, Strategy & Operations, Product, and Internal Audit to ensure effective controls across platform, marketplace, and payment flows.
- Prepare senior management and Board reporting on sanctions risk, policy changes, program effectiveness, and regulatory readiness.
- Maintain a centralized repository of audit findings, regulatory exam items, and self-identified issues; track remediation and validate closure.
- Support the Enterprise-Wide Sanctions Risk Assessment (SRA), ensuring outputs inform policy and control updates.
- Establish KRIs and KPIs to monitor sanctions program health.
- Align global governance with regional offices to reflect local regulatory regimes and product usage patterns.

Regulatory change management
- Monitor global regulatory developments and enforcement trends across sanctions regimes; lead impact assessments on systems, controls, and processes.
- Lead end-to-end change management for sanctions updates, including impact assessment, risk ranking, approvals, implementation, and post-implementation review. Act as the sanctions representative in New Product Approval forums.
- Maintain a formal change control process with versioning, documentation, audit trails, and release notes aligned with agile delivery.
- Partner with Operations and Engineering to ensure technical implementation of policy changes (e.g., screening logic and country blocklists).
- Draft Compliance Bulletins and support related training content.

Controls design and testing
- Design and oversee sanctions controls across onboarding, payments, monetization, advertising, and external integrations.
- Partner with Compliance Strategy and Product teams to configure, test, and tune sanctions screening systems and list integrations, managing false-positive and false-negative rates.
- Lead annual sanctions risk assessments and control testing, including issue management and remediation monitoring.

Training and awareness
- Develop and deliver sanctions training with the Compliance Training team for product, engineering, operations, customer support, and leadership.
- Drive ongoing awareness initiatives tailored to platform features.

Data governance and metrics
- Define and track sanctions KPIs with leadership dashboards.
- Promote data-driven, risk-based prioritization across regions and product teams.

Qualifications

Minimum qualifications:
- 5+ years of U.S. financial regulatory and sanctions compliance experience, with a strong emphasis on OFAC programs, fintech, and regulatory change management. Fintech, digital wallet, payments, identity, or social media platforms with global user bases and monetization programs.
- Deep knowledge of OFAC, EU, UN and MAS sanctions regulations, BSA/AML, FinCEN guidance, and related enforcement trends. Familiarity with OFAC, FinCEN, OCC, FDIC, Federal Reserve, and international sanctions authorities; understanding of cross-border payment flows and digital platforms.
- Demonstrated expertise in policy development, governance frameworks, risk assessment, and change management methodologies, preferably in an agile, product-driven environment.