The role of the Global Trading Compliance organization is to provide compliance advice, support and related services to the Shell Trading Businesses and Functions in a proactive, timely, cost-effective and professional manner with a view to furthering business objectives and protecting shareholder interests. The Global Trading Compliance organization seeks to ensure that compliance risks are identified and appropriate alternative approaches and strategies are considered in the conduct of business, at all times consistent with the Shell General Business Principles, the Code of Conduct and the rest of the Shell Control Framework. This role will support the Chief Compliance Officer (CCO) for Shell Trading Risk Management (STRM), an entity of Shell Trading North America (STNA). STRM is a registered swap dealer with the National Futures Association (NFA) and has extensive legal, regulatory and compliance requirements. As a registered swap dealer, STRM has ongoing, active oversight by the Commodities and Futures Trading Commission (CFTC).
Provide fit for purpose advice related to compliance expectations
with external regulations / internal requirements, or conformance with Group Standards, Manuals and Shell Trading Policies.
Prepare and deliver compliance training classes for STRM personnel or STRM support staff.
Attend senior management and leadership team meetings, including the STRM Board of Directors meetings, on behalf of the CCO.
Frequent direct interactions with Regulators (CFTC, NFA) on legal and compliance matters.
Provide advice and guidance related to the management and mitigation of regulatory and compliance risks such as market abuse, anti-trust, bribery & corruption, and money laundering.
Monitor proactively compliance with various Dodd-Frank requirements related to but not limited Customer Mark-to-Market Reporting, Large Trader Reporting, Swap Data Reporting, and Daily Valuation Reporting.
Liaise with functional groups from; Commercial, I.T., Confirmations, Contracts, Credit, Legal, Regulatory Affairs, Regulatory Reporting, and Risk Control; and other functions as needed. The STRM support staff consists of > 80 individuals across 12 different groups and functions.
Work with the STRM Leadership team, develop and agree to the compliance training plan / program (specific to the Group, and STRM) annually, and monitor completion. Oversee delivery of certain compliance-specific training.
Assist the CCO in preparing the Chief Compliance Officer Annual Report
Assist the CCO with drafting periodic and annual risk reports and any other regulatory filings.
Participate in the implementation of any operational changes necessary to meet external regulatory requirements that impact STRM. These efforts would include, but not be limited to, the requirements under the Commodity Exchange Act, U.S. Dodd-Frank Act and Canadian Derivatives Reform. Regulatory requirements to be implemented and monitored for compliance under these regimes include data recordkeeping and reporting to a swap data repository, business conduct standards and development of a risk management program.
Maintain the issue tracking tool of noncompliance or compliance risks that occur within the STRM organization; meet with various STRM functional stakeholders to determine causes of issues or risks; identify or determine controls or operational changes to prevent the recurrence of such instances or risks; and present this log on a weekly basis to the STRM CCO.
Assist the CCO to provide summaries of non-compliance instances or risks impacting the compliance of STRM operations with regulatory requirements to the STRM Board of Directors.
Coordinate the implementation of procedures designed to achieve regulatory compliance by identifying instances for procedural revision as necessary; work with necessary STRM Compliance, Legal, Regulatory, IT and other functional contacts to improve procedures.
Liaise with the North America Monitoring & Surveillance lead and the global Monitoring & Surveillance lead to ensure STRM compliance risks are addressed.
Execute other compliance-related tasks from time to time as necessary.
Support the Business Records Manager in ensuring that Compliance Records are appropriately managed in the Work Plan for STRM Compliance
Build and support a culture of compliance in Shell Trading through daily engagement with STRM operational functions and stakeholders, meeting to review compliance risks when necessary.
Independently assess and report on effectiveness of the STRM compliance program.
Work with the Business Governance Risk and Assurance (GRA) organization to ensure consistency and efficiency of the compliance effort, ensuring a strong link to the control framework across Shell Trading.
Educate and advise STRM Trading personnel and support staff on compliance risks and mitigations.
Monitor the external compliance landscape for significant issues that impact compliance program effectiveness (globally, by region, at country level).
Participate in crafting key Compliance messages for Town Hall meetings for CCO and Commercial leaders to deliver during sessions.
What we need from you
Must have legal authorization to work in the US on a fulltime basis for anyone other than current employer
Bachelor’s degree required (Business or equivalent preferred); Master’s degree preferred.
Minimum of ten (10) years of experience in an internal/external Compliance, Risk Control, Audit or SOX testing/controls or risk environment is required. This will include documenting business Compliance processes, identifying risks, designing and implementing mitigating controls, and developing remediation plans when there are Compliance related control failures
Experience implementing change, project management, cross-functional and cross-business teams
Strong commitment to compliance with strong relationship and influencing skills and the ability to address issues with senior leaders with diverse backgrounds
Ability to deliver on the accountabilities and responsibilities and drive action through influence in the midst of ambiguity and uncertainty; sound judgment in sensitive areas and on difficult issues
Able to motivate others and operate under pressure
Written, verbal and presentation communication skills
Evidence of strong relationship and influencing skills with senior leaders and people at all levels and in a range of cultures
Capacity to recognize and handle ever-changing mosaic of problems, adjusting priorities and allocating resources over tight deadlines
Excellent grasp of compliance as well as business issues, industry developments and legal, social and political trends that may have an impact on Trading
The ability to find creative solutions to compliance issues, but within acceptable legal and risk frameworks
An ability to understand and take account of business drivers and needs
The ability to clearly explain compliance risks, develop sound mitigation strategies and find acceptable commercial solutions
The ability to contribute at leadership team level and ensure that compliance issues are taken into consideration and complied with
Fluent in English, both spoken and written
Knowledge of Energy Trading or related industry experience along with familiarity of Dodd-Frank Title VII rules
Shell is a global group of energy and petrochemical companies with about 84,000 employees across more than 70 countries. We aim to meet the world’s growing need for more and cleaner energy solutions in ways that are economically, environmentally, and socially responsible. We have expertise in exploration, production, refining and marketing of oil and natural gas, and the manufacturing and marketing of chemicals.
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