Global Head of Anti Bribery Corruption and Anti Fraud Program


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In a nutshell


Veldhoven, Netherlands




8+ years



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Published: 13 days ago Job ID: J-00248627-476

Introduction to the job

ASML is seeking an experienced and qualified lawyer to head its global ABC and Anti-Fraud program, to be part of its worldwide Legal and Compliance team, based in Veldhoven (preference for NL but would consider Chandler, United States), who will drive implementation of the program, including establishing, embedding and enforcing elements of the program, with a goal to enhance the compliance mindset and maturity of the regional organization, and ensure that ASML continues to comply with FCPA, UKBA and other regional ABC legislation and operate with the highest standards of integrity and ethical conduct.

The position will report to the Chief Ethics Officer and work closely with the Ethics & Business Integrity team and the Chief Compliance Officer to establish the program and work with stakeholders to perpetuate a “tone at the top” at the country and regional level that reflects ASML’s commitment to compliance and embed a culture of high performance with integrity at all levels in the organization.

Role and responsibilities

Under the overall leadership of the Chief Ethics Officer, and in close coordination with the Chief Compliance Officer, enable and drive compliant and ethical business conduct through the effective implementation of the ABC and Anti-Fraud program at the global and region / country levels.This program includes other compliance topics such as Gifts and Entertainment, Conflicts of Interest and Anti Money Laundering.

Working closely with global and local stakeholders, the successful candidate will:
  • Establish and implement an ABC and Anti-Fraud program globally, driving the establishment and maintenance of procedures for the relevant policies at the headquarter and regional levels, and developing, implementing and coordinating a training strategy on these topics;
  • Stay abreast of the evolving FCPA and UKBA regulatory landscape and guidance along with industry leading practices in all relevant areas relevant to the ASML business and operations;
  • Ensure ABC and AF requirements under local law in the countries in which ASML operates are covered in the ABC & AF program;
  • Provide advice and guidance on ABC and AF topics, challenges and major initiatives;
  • Perform periodic risk assessments,where needed supportedby external legal counsel and ensure follow-up of risks identified
  • Provide proposed approach with regard to the ABC and AF program,implement controls and monitoring, preferably within existing processes;
  • Working closely with related functions (such as Finance, Risk & Business Assurance and HR), build and execute continued controls, monitoring and reporting for various policies and regulations in the defined compliance areas, including Anti-Bribery & Corruption, Anti Fraud, Gifts & Entertainment, Anti Money Laundering and Conflicts of Interest;
  • Maintain and continue to improve the training program for ABC, AF and related programs.
  • Work with the Ethics team to support ABC and AF related investigations.
  • Work with Communications to provide key compliance messages and to maintain high level of awareness (i.e. “tone at the top and at the middle”, implementation at all levels within the organization including in the field).
  • Work closely with local management, Legal & Compliance, Global Risk and Business Assurance,the Global Chief Compliance Officer as well as the Regional Heads of Legal and Compliance to drive the agenda and monitor follow up on agreed actions.

Education and experience

  • At least 12+ years of experience, in a legal setting, with both private practice and inhouse experience an advantage with at least 5+ years of experience in Anti Bribery and Corruption practice
  • Strong commitment to ethics and integrity;
  • Substantive knowledge of and ability to provide guidance on key compliance risk areas, such as ethics, anti-corruption and anti-bribery, and other critical areas.
  • Ability to quickly develop business acumen and learn the business processes, applications, and technologies;
  • Ability to influence others and lead;
  • Proactive, hands-on approach;
  • Fluent English required


Working at the cutting edge of tech, you’ll always have new challenges and new problems to solve – and working together is the only way to do that. You won’t work in a silo. Instead, you’ll be part of a creative, dynamic work environment where you’ll collaborate with supportive colleagues. There is always space for creative and unique points of view. You’ll have the flexibility and trust to choose how best to tackle tasks and solve problems.
To thrive in this job, you’ll need the following skills:

  • Strong analytical and problem-resolution skills, mature business judgment, and innovative thinking.
  • Ability to translate complex legal issues and ambiguity into concise, clear and practical advice and to communicate effectively with non-legal internal partners and stakeholders.
  • Ability to work independently, with minimal supervision, as well as collaborate with, and gain the respect of, co-workers and stakeholders at all levels and functions of the company.
  • Intellectually curious, open-minded and adaptable.
  • Committed to client satisfaction through focus on efficiency, prioritization, quality and professionalism.
  • Ability to complete assignments with attention to detail and high degree of accuracy.
  • Proven ability to perform effectively in a demanding environment with changing workloads, pressure and deadlines.
  • Possesses integrity and ethics in business, professional and personal conduct.
  • Demonstrate open, clear, concise and professional communication.

Diversity & Inclusion

ASML is an Equal Opportunity Employer that values and respects the importance of a diverse and inclusive workforce. It is the policy of the company to recruit, hire, train and promote persons in all job titles without regard to race, color, religion, sex, age, national origin, veteran status, disability, sexual orientation, or gender identity. We recognize that diversity and inclusion is a driving force in the success of our company.

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