The Regional BCF Manager, Latcan, represents the Business Controls Function (BCF) as a leader for Bristol-Myers Squibb's (BMS) commercial operations for Latin America, and Canada, helping support the Director, International Lead, and overseeing a team of local BCF associates that report to their respective market Finance Directors.  The position reports directly to the Director of International Risk Management, having responsibility for all Business Controls Function activities throughout the region, and serves on other BCF global initiatives.  The Manager provides essential guidance to commercial management and key business process owners in each market regarding internal controls, including Internal Controls over Financial Reporting (ICFR), compliance procedures and regulations, fraud risks, as well as corporate policies and directives.  Key to the Manager’s success is the knowledge and experience in the business unit and commercial market operations, experience serving multiple markets/clusters, the ability to collaborate with key management and provide guidance on the appropriate resolution of issues, and ability to gain the confidence and cooperation of the local managers to ensure appropriate input and dialogue on potential risks.  Key responsibilities are bifurcated between internal controls over financial reporting, risk assessment, and compliance-related anti-fraud, bribery and corruption monitoring activities.

MAJOR DUTIES AND RESPONSIBILITIES:

Sub-certification & SOX Activities

• Maintains strong understanding of the Company's Sarbanes-Oxley internal control standards and financial policies and procedures, including controls executed in the local markets.
• Works with business partners to proactively identify and assess emerging risk and control issuesas well as developing, monitoring and updating status of remediation plans..
• Actively evaluates out of period adjustments, control failures, Global Internal Audit & Assurance (GIA) Department observations, and SOX deficiency reporting from the local markets.
• Involved in the evaluation of all commercial market SOX deficiencies, including collaborating with the Business Process Champions and Process Owners as needed, to evaluate nature, remediation, severity, and possible pervasiveness of SOX deficiencies.
• Reviews markets' change in control reporting submissions and monitors change in control reporting submissions of the Region for timely submission, completeness, and accuracy. Identify and work with management and the local BCF to implement steps to mitigate risk and evaluate control environment impact of changes as necessary.  Maintains own point of view on potential control environment changes in the commercial markets under scope of responsibility through active engagement with stakeholders and discussion of risk.
• Monitors and updates the Current Status of Audit Recommendation (CSOAR) for the region to ensure timely and thorough remediation of internal audit findings.
• Ensures thorough and prompt remediation of all SOX deficiencies and audit observations with robust documentation and descriptions of remedial activity.  Documents and/or reviews and approves the adequacy of  Regional closure activities for all remediation documented by local BCF.
• Ensure timely submission of market management rep letters and evaluates any exceptions disclosed.
• Prepares quarterly sub-certification reports and prepares summary of regional activity, including outstanding SOX deficiency, open and remediated internal audit recommendations, changes in the control environment, anti-fraud, bribery and corruption monitoring results, and other significant market developments for the Director of International Risk Management.
• Participate in and support regional process redesign and/or system implementations, providing an internal controls perspective to the team and liaising with the Business Process Champion for the respective process cycle.
• Anti-fraud, Bribery & Corruption Monitoring
• Review region's expenditures monitoring exceptions , in conjunction with the Associate Director, Risk Management, for indicia of fraud, bribery or corruption, inappropriate healthcare professional interactions, and industry code violation for potential escalation to BCF leadership and the Compliance & Ethics Department. 
• Executes on-going regional expenditures monitoring utilizing data analytics (i.e., accounts payable, travel and entertainment and purchase card expenditures), with assistance from Local BCF.  Triage of high and medium risk transactions for indicia of fraud, bribery or corruption, prior to forwarding potential exceptions to the markets.
• Contribute to the on-going maintenance and update of data analytics scripts to ensure that local market risk is addressed and false positives are minimized.
• Respond to market inquiries regarding severity of issues identified and escalation to the BCF's Director of International Risk Management when necessary.
• Monitors dashboarding to ensure that exceptions are analyzed promptly and for trends and leading indicators of risk.
• Investigative Support
• Provide investigative support under Compliance & Ethics and the BCF Director of International Risk Management's supervision on an ad hoc basis.
• Governance, Hiring & Training
• Provide framework and governance that may include work instructions, training, day-to-day responses to inquiries and support of local market BCFs activities and as other risks arise (e.g., operational issues).
• On-boarding and on-going training of all new local BCF.
• Responsive to day-to-day inquiries from key stakeholders within the BCF and the operations
• Maintains strong stakeholder engagement with local BCF, local Finance Directors and other members of commercial market management through 1:1’s to discuss issues of risk and remediation, and escalation of issues to corporate BCF leadership as necessary.
• Financial, Operational & Fraud Risk Assessment
• Oversees the regional markets’ financial, operational and fraud risk assessments.
• Maintains own risk assessment and point of view on risk and BCF operations separate and distinct from the market risk assessments for presentation to the BCF's Director of International Risk Management and Executive Director.
• Monitors higher risk areas identified in risk assessment and reviews if mitigation actions are in place and effective.
• Ensures department BPCs are consulted prior to recommending any changes to globally designed controls, processes or procedures (including locally executed controls that differ from globally designed controls/end-to-end process).
• Assist in evaluation of potential changes in processes and procedures to ensure stability of control environment and avoidance of detrimental impact to the financial statements.
• Audit Support
• Assist and support as necessary local operations and Finance with internal and external audits.  This is generally a local market BCF task, but for certain regional or corporate audits, the Manager may serve as the primary point of contact for the BCF. 
• BCF Finance Project Management
• Participate in and/or lead special projects and data analytics initiatives, including systems implementations from a financial control and compliance perspective and projects to improve and automate BCF governance and operations.
• Third-party Risk Management
• Aid in setting third party risk management program agenda and risk assessment, establishing annual monitoring plan, and communicating to the BCF network and commercial markets.  Works with local markets to identify potential candidates for monitoring engagements.