Export and Trade Sanctions Compliance Manager

Job Purpose

The Export and Trade Sanctions Compliance Manager will be responsible for developing, implementing, and overseeing a robust export control and trade sanctions compliance program, as well as a consistent Third-Party Due Diligence (TPDD) program across the Recordati Group.
Reporting directly to the Group Compliance and Ethics Officer, this pivotal role will serve as the subject matter expert on export control, sanctions and TPDD matters, providing guidance, training, and oversight to relevant departments globally, ensuring adherence to applicable international and national regulations, industry standards, and Group Policies.

Key Responsibilities

1.    Export, Trade Sanctions and Third-Party Due Diligence (TPDD) Compliance Programs Development:
•    Develop, implement, and maintain written global export control, trade sanctions and TPDD policies, procedures, and guidelines tailored to the operations of the Recordati Group. 
•    Establish and maintain internal controls to prevent unauthorized exports, re-exports, and transactions with sanctioned or high-risk entities or individuals across all global operations.
•    Stay abreast of changes in export control regulations and trade sanctions imposed by relevant authorities (e.g.: EU, UK, US, UN).
•    Develop and disseminate global export control, trade sanctions compliance and TPDD tools, templates, and resources.
•    Conduct in-depth due diligence assessments on prospective and existing high-risk business partners.
2.    Global Support and Consistency:
•    Ensure consistent application of global export control, trade sanctions and TPDD policies and procedures across the Recordati Group.
•    Act as a central point of contact for export, trade sanctions and TPDD matters within the Group, facilitating communication and knowledge sharing across different entities.
•    Identify potential risks and provide recommendations for corrective actions.
•    Promote cross-country collaboration and knowledge sharing among relevant personnel.
3.    Training and Education:
•    Develop and deliver comprehensive global training programs on export control, trade sanctions compliance and Third-Party risks to relevant employees.
•    Promote a culture of compliance and awareness regarding export, trade sanctions and Third-Party risks throughout the organization.
4.    Monitoring and Reporting:
•    Develop and implement adequate monitoring programs.
•    Prepare and present regular reports to the Group Ethics and Compliance Officer and other senior management.
•    Perform compliance reviews and due diligence on customers, distributors, and other business partners.
5.    Risk Management:
•    Identify and assess compliance risks related to export activities and trade sanctions, as well as other compliance risks associated with Third Parties, (e.g.: corruption, human rights abuses, etc).
•    Developing and implementing mitigation strategies in collaboration with relevant departments and local entities. 
•    Monitor and track relevant regulations globally, providing timely guidance to relevant stakeholders.
6.    Liaison and Communication:
•    Collaborate closely with Legal & Compliance, Regulatory Affairs, Quality, Supply Chain, Sales, Finance, Procurement and other relevant departments on issues related to export controls, trade sanctions and compliance / reputational risks related to Third-Parties.

Required Education

Master’s degree in international Trade, Business Administration, Law, Supply Chain Management, or a related field. An advanced degree is a plus.

Required Skills and Experience

•    Minimum of 10 years of experience in export control and trade sanctions compliance within a global pharmaceutical organization, ideally complemented with an experience in managing Third Party Due Diligence programs. 
•    In-depth knowledge of relevant export control regulations (e.g., EU Dual-Use Regulation, US EAR) and trade sanctions regimes (e.g., EU sanctions, UK, US OFAC sanctions, UN sanctions).
•    Strong knowledge of anti-bribery and anti-corruption laws (e.g.: FCPA, UK Bribery Act).
•    Familiarity with pharmaceutical supply chains, manufacturing processes, and product classifications in a global context.
•    Strong analytical, problem-solving, and risk assessment skills.
•    Excellent communication, presentation, and interpersonal skills, with the ability to interact effectively with individuals from diverse cultural and professional backgrounds.
•    Ability to work independently and collaboratively across different departments and global entities.
•    Strong ethical standards.

Required Languages

Fluency in English is required; fluency in Italian and other languages relevant to Recordati’s global operations is a significant advantage.