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In this role you will support and enhance the anti-corruption, trade, and privacy law compliance program for SAS Institute Inc.
s global operations focusing primarily on SAS’ operations in the Asia Pacific region ( AP ).
This individual will report to SAS’ global headquarter and will collaborate with and receive guidance from the SAS Senior Principal Compliance Counsel responsible for global anti-
corruption compliance, as well as the Regional General Counsel. This person will serve primarily as the regional anti-corruption law subject matter expert and will provide oversight of anti-
corruption compliance for AP operations. This person will also act in a secondary support role as a liaison between the Ethics and Compliance team at headquarters and regional counsel and business unit leaders to facilitate SAS’ global strategy and compliance program, including compliance with (1) export and import law compliance matters such as trade sanctions and anti-
boycott law compliance and (2) privacy and data compliance matters.
The individual should be able to consider compliance efforts in the broader organizational compliance context, and will work in a cross-
functional capacity, consulting and advising various groups within the organization. The individual should be able to manage and prioritize among multiple projects.
Job Responsibilities :
Build Work creatively to implement SAS’ compliance policies and processes at the regional level, including internal processes to assess and address risks of corruption in SAS’ business operations and initiatives, all in coordination with global anti-
corruption strategies and applicable international, national, and local laws and requirements.
Localization : Work with local in-house and outside counsel to perform a gap analysis on SAS’ global anti-corruption program in comparison to local office anti-
corruption compliance programs, and make modifications to meet local law requirements in countries like China, Malaysia, India, and others .
Regulatory Review : Assist government affairs and compliance counsel with reviews and commenting on proposed anti-corruption and trade law legislation and regulations affecting the organization’s regional and global operations.
Training : Educate employees concerning the company’s compliance program through formal presentations. Assist in providing guidance and training through the AP organization on compliance matters.
Maintain and Repair Coordinate with Senior Principal Compliance Counsel, Regional General Counsel, local legal counsel, Human Resources, Chief Privacy Officer, Chief Privacy Strategist, Chief Information Security Officer, Finance, Internal Audit, Sales, and other staff and business units, and outside resources on due diligence, investigations, audits and assessments as needed to address compliance issues as they arise and to prevent future recurrences.
Refine Assist multiple business functions in continuous review and improvement of business processes to ensure anti-corruption, trade, and privacy law compliance measures are considered and included and to make compliance processes work seamlessly and ever more efficiently with the company’s sales and development efforts.
Support industry benchmarking, self-assessments and audits to detect and remediate anti-corruption program gaps.
Maintain continuing contact with regional operational employees to understand risks generated in the region and surface and address those risks through SAS’ global compliance program, with local variations as needed.
Draft, maintain and manage the execution and submission of contract provisions and documentation to ensure compliance with applicable anti-corruption laws.
Create legal guidance materials for SAS counsel to use in negotiation of compliance provisions in contracts and requests for proposal.
Other duties as assigned and necessary within the company to ensure compliance policies are maintained corporate wide and to promote the company’s ethics and compliance program, including assisting with the administration of the corporate-
wide trade law and data privacy and security programs.
JD or equivalent degree from an accredited law school
5 or more years of legal experience
Licensed to practice law by an authorizing entity of an AP jurisdiction at a level similar to being admitted to and a member in good standing of at least one U.S. state bar
Understanding of global anti-corruption laws and regulations, including in particular the United States Foreign Corrupt Practices Act (FCPA) and United Kingdom Bribery Act, and familiarity with United States export laws
Native or nearly native speaking and writing proficiency in English and Mandarin
Prior experience managing compliance initiatives
Working knowledge of local and international anti-corruption law compliance and regulatory requirements and compliance best practices
Previous experience in legal and regulatory compliance and corporate investigations
Education or experience in the field of cryptography and International Traffic in Arms Regulation compliance
Familiarity with software development and distribution processes
Experience in the software, cloud computing and information technology services sectors
Previous in-house corporate counsel and regulatory compliance experience
Familarity with the region through travel and assignments in various countries
Excellent verbal and written skills; proficiency in additional AP languages in addition to English and Mandarin; strong personal computer skills
Proactive team player that garners respect on and off the job
Equivalent combination of education, training, and relevant experience may be considered in place of the education requirement stated above.
Location and Travel :
This position will preferably be based in Hong Kong or Singapore, or one of SAS’ other main AP offices with a requirement to travel occasionally throughout AP.
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