The Square Product Compliance Management (PCM) team partners with cross-functional stakeholders to design and build remarkable solutions that meet relevant regulatory compliance obligations.
We achieve this mission by: i) embedding with Square product teams to provide ongoing advisory compliance support, including support for new product development and product capability enhancements; ii) building trust and credibility through strong relationships with cross-functional stakeholders (e.g. Legal, Risk, Compliance Operations); and iii) engaging in creative problem-solving to tackle complex problems.
Understanding someone’s struggle → PCMs will put themselves in the business shoes to help them build a product for the problem Square is solving.
Seeking divergent perspectives → PCMs will listen to all stakeholders to understand the product in depth
Taking principled risks → As appropriate, PCM will take a principled risk approach and ensure there are controls and processes in place to protect Square’s reputation and comply with relevant regulatory compliance obligations
Lead with a Solution-Oriented Approach → PCMs will investigate regulatory expectations and industry best practices to propose the best solutions for Square
Square PCM works with cross-functional stakeholders to compile Compliance Requirements Documents (CRD). CRDs are provided to the business as the single source-of-truth for what is required from a compliance perspective before a product capability can be launched. CRDs include all relevant regulatory requirements, including AML and non-AML requirements.
The Square Product Compliance team is responsible for:
1. Providing ongoing advisory compliance support to product teams;
Ongoing Advisory Compliance Support
PCMs will provide anti-money laundering (AML) and product compliance advisory to Product Teams. This includes:
Supporting requirement identification for new products and features
Addressing queries on policy and procedure interpretation
Advising on compliance risks related to control issues
2. Identifying and documenting applicable compliance requirements in CRDs
PCMs will identify the compliance risks of any new or existing product through the CRD;
PCMs will track implementation of product-specific compliance requirements in the CRD to support product launch milestones (e.g. alpha, beta, general availability);.
Legal will provide the set of requirements and PCMs will translate those into the CRD
PCMs will escalate to the PCM lead any compliance-related obstacles in product launches
3. Ensuring compliance controls are implemented and working as intended to enable product launch.
PCMs will work closely with Product Managers (PMs), Engineering and Operational teams to build applicable compliance and product controls
PCMs participate in:
1. Risk Assessment (RA)
PCMs will contribute to update the BSA/AML PRA annually, and on an ad-hoc basis based on the occurrence of any of the below triggering events:
Changes to laws and regulations;
New or changed business activities;
Risk incidents that pose BSA/AML risk to Square;
Internal audit findings that reveal a lack of control effectiveness or need for additional controls; and
Self-identified issues that reveal a lack of control effectiveness or need for additional controls
2. Program document management
PCMs will propose improvements to compliance policies and procedures when needed to achieve compliance with applicable laws and regulations
PCMs will partner with the Compliance Governance Training team to review compliance policies and procedures and update as required