Senior Lead, Trade Compliance

Role Purpose 

The Senior Manager, Global Compliance Risk Assessment designs and runs ASM's global compliance risk assessment program. The main focus is export control, with wider coverage of general compliance risks. The role gives leadership a clear, data-driven view of compliance exposure and makes sure risks are identified, prioritized and mitigated before they affect the business. In doing so, it protects market access, revenue and reputation. 

Key Responsibilities 

1. Global Risk Assessment Framework

• Design, implement and maintain a risk-based framework for export control and general compliance across all regions and business units. 

• Define the risk methodology, including scoring, likelihood and impact criteria, risk appetite and escalation thresholds. 

• Run the annual global compliance risk assessment and targeted assessments when the business or regulations change. Examples include new markets, products, customers and export control developments. 

1. Export Control Risk (Primary Focus)

• Assess risks under U.S. (EAR), EU (Regulation 2021/821), Japanese, Singapore, Korean and Chinese export control regimes. 

• Evaluate exposure in high-risk areas, such as:  

• Classification 

• Licensing 

• End-use and end-user due diligence screening 

• Technology transfer and deemed exports 

• Spare parts and service 

• U.S. Persons Rules 

• Assess the business impact of new regulations, such as BIS rules, entity list expansions and China countermeasures, and translate it into concrete mitigation actions. 

• Test the effectiveness of the Internal Compliance Program (ICP) and of system controls, for example in ERP and Teamcenter. 

1. General Compliance Risk

• Extend risk assessment to general compliance related risks. 

• Work with Internal Audit so there is one consistent view of risk and no duplication. 

1. Monitoring, Testing and Assurance

• Develop and carry out a risk-based compliance monitoring and testing plan, including site and process reviews in Europe, the U.S. and Asia. 

• Identify control gaps and root causes, agree corrective actions with the business, and track them to closure. 

• Prepare the organization for regulator inquiries, government audits and external reviews. 

1. Reporting and Governance

• Produce clear, executive-level risk reporting for the Corporate Director, the Management Board, the Audit Committee and the Supervisory Board. 

• Maintain the compliance risk register and key risk indicators (KRIs). 

• Turn complex regulatory risk into business terms such as revenue at risk, operational disruption and reputational impact. 

Qualifications and Experience 

Required 

• Master's degree in Law, Business, Economics, International Trade, Finance or a related field. 

• At least 7 years of relevant experience, including significant experience in internal audit, compliance risk assessment or risk management. 

• Proven track record of designing or running risk assessment or audit programs in a multinational environment. 

Competencies 

• Analytical and risk-based thinking, with the ability to set priorities 

• Business acumen: positions compliance as a business enabler, not a barrier 

• Clear, concise communication at executive and Board level 

• Independence, integrity and sound judgment 

Travel 

International travel of about 20–30%, mainly to the U.S. and Asia.