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Product Compliance Management Team

Why are we here?
Our Mission
Square is fully committed to the fight against financial crime and makes every effort to ensure our product/services offerings remain compliant with applicable laws, regulations and standards in all jurisdictions in which we operate.
Doing so allows us to prevent and detect possible criminal behavior, protect our reputation, and to meet legal and regulatory obligations.
As an organization committed to Compliance, Square requires clear lines of internal accountability and responsibility. This document sets out roles and responsibilities of the Product Compliance Team

Our Values
Understanding someone’s struggle → PCMs will put themselves in the business shoes to help them build a product for the problem SQ is solving.
Seeking divergent perspectives → PCMs will listen to all stakeholders to understand the product in depth and will brainstorm on potential controls
Taking principled risks → PCMs will prioritize risks and set a plan to set the right controls in place to keep Square safe
Inventing & Learning → PCMs will investigate regulatory expectations and industry best practices to propose the best solutions for Square

things we talk about
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The Product Compliance team is responsible for:
Providing ongoing advisory compliance support to product teams;
Identify and document applicable compliance requirements for the launch of new products; and
Ensure compliance controls are implemented and working as intended
🏀 Meet the Square Product Compliance team
Vishal

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Landon

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Amanda

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Lucia

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PRC team
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Name
Contact
Title
Area
Timezone
1
Vishal Melwani
@Vishal Melwani
Product Compliance Lead
All of the below!
EST
2
Landon Hill
@lhill@squareup.com
Product Compliance Manager
Square Banking, Intl Loans
AZ
3
Amanda Wang
@amandaw@squareup.com
Product Compliance Manager
Checking, Debit Card, Transfers, Credit Card
EST
4
Lucia Marin
@luciac@squareup.com
Product Compliance Manager
Square Processing
EST
There are no rows in this table
🎯 Primary responsibilities
PCMs are responsible for:
1. Providing Compliance Advisory to Product Teams
Product Advisory
PCMs will provide anti-money laundering (AML) and product compliance advisory to Product Teams. This includes:
Supporting requirement identification for new products and features. Not all products require a CRD! PCMs will assess whether a CRD is needed or not upon a product review.
Addressing queries on policy and procedure interpretation
Advising on compliance risks related to control issues
Regulatory Change Monitoring
PCMs will monitor significant regulatory changes impacting Square product/services offerings.
PCMs will draft and circulate internal communications on relevant regulatory updates.
PCMs will work with in-country PCMs, who maintain sole responsibility for ensuring products and services offered within their jurisdiction meet local regulatory expectations.
2. Managing the Compliance Requirements Document (CRD)
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. Supporting Control Implementation
PCMs will closely with Product Managers (PMs), Engineering and Operational teams to build applicable compliance and product controls
PCMs will contribute to the Product Control Monitoring Program (is this something we have in place at SQ?) by documenting controls designed to ensure products, features and bank partnerships align to policy standards.
PCMs participate in:
1. Product Risk Assessment (PRA)
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 review compliance policies and procedures annually and update them when required
The PCM Lead will be responsible for:
1. CRD approval
Reviewing and approving CRDs in a timely manner, providing inputs from their respective domains, and assessing functional impacts (e.g. resourcing, training, tooling, etc);
2. Control implementation
Collaborating with PCMs to agree what specific controls are required and when they must be delivered (i.e. beta vs general availability);
Tracking implementation of any ad hoc (non-standard) controls and flagging potential delays to PCMs in a timely manner.
3. Reporting and escalation
Reporting to the following committed n on product compliance risks:
Audit and Risk Committee - Quarterly reporting of main developments occurred during the quarter
xxx - Monthly reporting
Escalating to senior management compliance-related any compliance risk incident

The PCM team is here to support Square in launching products that adhere to applicable regulatory requirements


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