Sanctions Risk Senior Manager

Tencent; Hong Kong; On-site; HKD 900,000 - 1,500,000; Full time

Job summary

Tencent seeks a Sanctions Risk Senior Manager to lead the Group's sanctions compliance function and build capabilities globally. You will design governance, drive risk appetite, and oversee screening, monitoring, and complex investigations across multiple jurisdictions.

You will coordinate with legal, risk, and engineering teams to deploy RegTech, AI-enabled name matching, and data platforms, while mentoring a top-tier team and shaping compliance culture.

Qualifications

• 8+ years in sanctions, AML, or financial crime compliance
• 3+ years of team leadership
• Deep knowledge of OFAC, EU, UK, and UN sanctions frameworks
• Experience advising on cross-border business operations, preferably in tech/fintech
• Hands-on exposure to screening or monitoring systems; RegTech solutions deployment
• Fluent in English and Mandarin; ability to engage with external counsel

Responsibilities

• Design and improve the sanctions compliance framework, policies, and procedures across all business lines
• Lead enterprise-wide sanctions risk assessments across geographies and products
• Provide sanctions compliance review and strategic advice for cross-border expansion, M&A, and payments
• Oversee sanctions screening programs and list governance (OFAC SDN, 50% Rule)
• Define RegTech roadmap and drive AI/automation for screening and monitoring
• Build and mentor a high-caliber sanctions team and drive risk culture

Skills

Sanctions leadership

Team leadership 3+ yrs

OFAC/EU/UK/UN knowledge

Cross-border business advisory

RegTech familiarity

English & Mandarin fluency

Pragmatic decision making

Education

Bachelor's degree (Law, Finance, Intl Trade, Econ, CS)

Tools

SQL

BI tools

RegTech systems

Job description

• Provide sanctions compliance review
• Education: Bachelor's degree or above (Law
• Lead the assessment, escalation, and resolution

About the Role

As our global footprint expands across social, content, fintech, cloud computing, and enterprise services, the complexity of international sanctions compliance — spanning OFAC, EU, UK, and UN regimes — has grown significantly. We are seeking a Sanctions Risk Senior Manager to build and lead the Group's sanctions compliance function from the ground up.

What You Will Do

Sanctions Framework & Governance

• Design and continuously improve the Group's sanctions compliance framework, policies, and procedures across all business lines and jurisdictions.
• Define the Group's sanctions risk appetite and tolerance thresholds; establish clear roles and collaboration mechanisms across the three lines of defense.
• Lead periodic enterprise-wide Sanctions Risk Assessments across business lines, geographies, customer segments, products, and channels.

Business Advisory & Decision Support

• Provide sanctions compliance review and strategic advice for critical scenarios: overseas market expansion, cross-border payments and settlement, international M&A and investment, global supply chain procurement, etc.
• Lead the assessment, escalation, and resolution of complex sanctions matters and significant risk events.
• Manage sanctions-related regulatory inquiries, external counsel coordination, internal investigations, and potential disclosures.

Sanctions Screening & Operations

• Oversee the screening program for customers, counterparties, vendors, and payment transactions; manage false positive resolution and hit investigation workflows.
• Govern the sanctions list database (OFAC SDN, sectoral lists, 50% Rule affiliates, etc.), including list maintenance, update cycles, and matching logic.

RegTech & AI Transformation (Key Focus)

• Define and own the sanctions RegTech roadmap to drive digitalization, automation, and intelligent upgrade of screening, monitoring, and due diligence processes
• Lead the integration of AI technologies (LLMs, machine learning, entity resolution) to enhance name matching accuracy, alias recognition, complex ownership tracing, suspicious pattern detection, and false positive reduction
• Design real-time sanctions monitoring and interdiction capabilities for fintech scenarios (cross-border payments, digital wallets, clearing & settlement)
• Establish AI model governance mechanisms to manage model risk, explainability, data quality, and bias for auditable AI-assisted decisions
• Drive the development of a compliance data platform to integrate sanctions risk data, enable visualization, and operationalize Key Risk Indicators (KRIs)
• Contribute the compliance perspective to the Group's AI governance across the full AI lifecycle — identifying compliance risks in AI applications (e.g., data and algorithms) and collaborating with legal, engineering, risk, and data security teams to embed compliance controls by design.

Team & Culture

• Build, manage, and mentor a high-caliber team that combines deep sanctions expertise with technology fluency.
• Drive sanctions compliance training and risk culture across business, legal, engineering, and risk functions.

Who You Are

Must-Have

• Experience:8+ years in sanctions, AML, or financial crime compliance, including 3+ years of team leadership
• Sanctions Depth: Deep working knowledge of the U.S. OFAC sanctions regime (including secondary sanctions, the 50% Rule), plus EU, UK, and UN sanctions frameworks
• Business Acumen: Proven experience advising on cross-border business operations, preferably in the technology, fintech, or internet sectors
• RegTech Familiarity: Hands-on exposure to screening or transaction monitoring systems; ability to evaluate, select, and deploy RegTech solutions
• Communication: Fluency in written and spoken English and Mandarin; ability to interpret English-language regulations and engage with external counsel
• Judgment: Track record of sound, pragmatic decision-making in regulatory grey areas
• Education: Bachelor's degree or above (Law, Finance, International Trade, Economics, Computer Science, or related fields preferred)

Nice-to-Have

• Certification: CAMS, CGSS, or equivalent professional credentials
• Institutional Background: Experience at a multinational corporation, global financial institution, top-tier law firm, or regulatory body
• AI & Data: Ability to use SQL or BI tools for risk quantification; exposure to AI/ML model governance in a compliance context
• AI Governance: Familiarity with AI governance frameworks, algorithmic compliance, model lifecycle management, or AI ethics

What We Offer

• A career-defining leadership role building and leading the sanctions compliance function of a premier Chinese technology group during its global expansion, with significant organizational impact and room for growth.
• Competitive compensation (base + equity) and comprehensive benefits.
• Collaboration with world-class compliance, legal, engineering, and business teams.

Diversity, Equity & Inclusion at Tencent

Diversity, equity and inclusion are important, interdependent components of our workplace. As an equal opportunity employer, we firmly believe that diverse voices fuel our innovation and allow us to better serve our users and the community. We foster an environment where every employee of Tencent feels supported and inspired to achieve individual and common goals.