Senior Managing Counsel, Corporate Compliance

Role Description

About the role

This role is the principal legal advisor on corporate compliance matters for Booking.com and a key senior legal partner to the Booking Holdings Compliance & Ethics program. The Senior Managing Counsel, Corporate Compliance provides strategic legal counsel and oversight on high‑impact compliance questions, shaping how Booking.com interprets and applies its legal and ethical obligations in practice.

The Senior Managing Counsel delivers risk‑based legal advice on complex and often cross‑border regulatory, criminal and ethics‑related matters, including direct counselling of senior leadership. They define and interpret the legal standards for the corporate compliance program by advising on regulatory risk assessments, remediation, control design, contractual requirements and escalation frameworks executed by compliance and business teams. The role also monitors global legal and regulatory developments, advises on embedding a strong culture of integrity across business units and regions, and leads or oversees high‑severity matters with potential criminal, regulatory or significant reputational impact, ensuring outcomes that are defensible, proportionate and aligned with Booking.com’s values.

Key responsibilities

Strategic legal advisory leadership

• Act as the principal legal advisor for corporate compliance topics globally, partnering with the Deputy Chief Compliance Officer, Legal & Public Affairs (LPA) leadership, the Compliance & Ethics Leadership Team (C&E LT) and business leadership teams to connect dots across C&E functions and provide cohesive legal advisory support.
• Serve as the compliance legal lead for certain business units or corporate functions, providing integrated legal and compliance advice and coordinating with C&E functions: Financial Crime, Human Rights, Regulatory Compliance, and other relevant stakeholders.
• Serve as principal legal counsel for Gifts & Entertainment and Conflict of Interest, defining legal standards, advising on complex approvals and escalations, and ensuring these requirements are appropriately reflected in policies, processes and contracts.
• Shape compliance‑related legal positions and strategies for high‑impact initiatives, including product launches, new business models, strategic partnerships, and responses to regulatory or law enforcement inquiries.
• Ensure that Booking.com’s corporate compliance program is anchored in strong legal analysis, aligned with BHI’s standards and industry best practice, and calibrated to Booking.com’s risk appetite.

Compliance program leadership and governance

• Provide legal and strategic counsel to the corporate compliance program team on the Booking.com Compliance & Ethics program (as jointly developed between BHI and Booking.com), partnering closely with the Corporate Compliance Program lead to ensure that relevant policies, processes and tools are effectively communicated, embedded into business practices and periodically refreshed in line with legal and regulatory developments.
• Day‑to‑day design, administration and operationalisation of the Compliance & Ethics program is owned by the corporate compliance program operations team; this role provides legal oversight, challenge and counsel.
• Ensure and monitor the implementation and effectiveness of compliance controls and programs, including by conducting or overseeing:

• Enterprise and program‑level risk assessments
• Review and follow‑up of relevant internal audit findings and other monitoring activities
• Provide legal advice for, and oversee (and where appropriate conduct), targeted compliance risk reviews on specific topics, functions or processes, with a strong focus on compliance risks, controls and remediation recommendations from a legal perspective.

• Ensure that learnings from investigations, audits and reviews are systematically fed back into the corporate compliance program, including updates to policies, training, controls, risk assessments and reporting.
• Provide senior legal advisory support on criminal‑related matters that impact the company (e.g. fraud, bribery and corruption, employee or partner misconduct with potential criminal dimensions).
• Contribute to the definition and delivery of Compliance & Ethics objectives and KPIs, partnering closely with the Corporate Compliance Program lead and other key stakeholders at BHI and across Legal & Public Affairs and the business.
• Support Booking.com and/or BHI C&E Financial Crime, Human Rights Risk Management, and Regulatory Compliance teams and other relevant leaders with respect to implementing compliance controls, risk assessments, due diligence, coordinating training and awareness, and helping to produce key performance indicators.

Contracts, escalations and commercial enablement

• Ensure compliance requirements are appropriately and consistently reflected in contracts and commercial arrangements (e.g. sanctions/AML clauses, ABC, economic crime, human rights, Code of Conduct, audit and cooperation provisions), in close collaboration with C&E LT, Legal, Procurement and commercial stakeholders.
• Provide senior legal review and sign‑off on higher‑risk transactions, partners and proposals, acting as an escalation point and issuing risk‑based recommendations consistent with Booking.com’s legal and compliance standards and notification matrices.
• Support or lead negotiations on compliance‑related contractual provisions with key partners and vendors, balancing legal/compliance risk with commercial objectives and clearly documenting legal analysis and decision‑making.

Reporting, innovation and continuous improvement

• Provide day‑to‑day people leadership to at least one junior lawyer (and any additional team members as required), including goal‑setting, coaching, feedback and supporting professional development, ensuring high standards of legal quality and integrity.
• Coordinate and provide periodic reporting to senior management on Compliance & Ethics program initiatives, including but not limited to: program maturity and effectiveness; key risk indicators and performance against KPIs; investigations metrics, key themes and legal risk insights.
• Innovate and improve day‑to‑day activities to increase the quality, scalability and efficiency of compliance processes and programs, including use of technology, data and analytics, while maintaining appropriate legal rigour.
• Role‑model senior leadership behaviours (strategic impact, autonomy, stakeholder leadership, coaching and talent development) and exemplary legal craft.

Key skills and experience

• 8–12 years’ relevant post‑qualification experience as a compliance officer in-house and/or legal counsel supporting compliance programs, including investigations and enforcement matters.
• Educated to degree standard in law; admission to practice in at least one jurisdiction strongly preferred.
• Significant in‑house experience as a compliance officer or compliance counsel in a large, multi‑jurisdictional organisation (ideally in technology/digital platform environments).
• Demonstrated ability to operate as senior legal counsel while owning and driving compliance program responsibilities (not only advisory work).
• Proven experience leading or supporting regulatory change initiatives, including translating new laws and regulations into practical controls and business processes.
• Demonstrated experience in regulatory risk and gap assessments and implementation of new or evolving regulatory requirements.
• Skilled in using risk assessments and control design to inform prioritization, remediation and governance discussions with senior leadership.
• Experience managing and embedding compliance requirements in contracts and commercial arrangements, including handling complex legal escalations.
• Strong track record supporting or leading negotiations on compliance-related contractual provisions with key partners and vendors.
• Experience advising on, or handling, criminal‑related matters involving companies, employees or third parties (e.g. fraud, bribery and corruption, sanctions/AML, economic crime).
• Investigations experience: planning, conducting and/or overseeing internal investigations and remediation, ideally including interaction with regulators or law enforcement.
• Comfortable managing external counsel and coordinating multi-stakeholder responses in high-severity matters.
• Excellent written and oral communication skills, with confidence in delivering compliance and legal guidance and training at all levels of the business, including senior leadership and Boards.
• Proven professional and collaborative approach, with strong stakeholder management skills and the ability to influence and persuade without relying on formal authority.
• Ability to translate complex legal and regulatory concepts into clear, business-relevant guidance and options.
• Demonstrated ability to work independently with high autonomy, while exercising sound judgement on when to escalate or seek alignment.
• Proven people management experience, including managing, mentoring and developing lawyers or other legal/compliance professionals, and providing clear, balanced performance feedback.
• Strong organisational skills and ability to manage multiple complex priorities across geographies and time zones.
• Evidence of role-modeling integrity, accountability and ethical leadership, including in ambiguous or high-pressure situations.
• Willingness and availability to travel globally.

Further traits we look for

• Alignment with Booking.com’s values (Customer First, Succeed Together, Own It, Learn Forever, Do the Right Thing).
• Curiosity, flexibility, and a creative, pragmatic approach to problem-solving.
• Confidence with collaboration.
• Ability to influence stakeholders at all levels.
• Proactivity, resilience, and a drive to deliver results.
• Strong judgment with attention to both the big picture and key details.
• Courage to take a stance and make tough decisions.
• Team-oriented, self-aware, and a good listener.
• Agility in prioritizing and meeting deadlines.
• Forward-thinking, with a focus on emerging legal and policy issues.

Why join the Legal & Public Affairs Team now?

This is a pivotal moment in e-commerce and travel, and joining Booking.com’s Legal & Public Affairs (LPA) team provides you with opportunities to shape the future. The LPA team plays a key role in enabling Booking.com to become a one-stop solution for all travel-related needs, from accommodation to rental cars, flights and attractions, and beyond. As a member of the LPA team you will partner with the business to navigate complex regulations, build new products, and negotiate key deals—while driving ethical, sustainable growth.

Who we are

We are an award winning team of around 200 professionals from 36+ nationalities, with lawyers qualified in multiple jurisdictions and non-lawyers specializing in public policy, economics, compliance, and risk. We have been recognised and shortlisted individually and as a team by the Legal 500 GC Powerlist, Assoc. of Corp Counsel, Global Competition Review, The Lawyer GC of the Year (shortlisted), Compliance Week and the Financial Times. We encourage active participation in the industry, with board membership and representation at industry bodies at multiple levels.

As a team, we believe in

• Being integral to decision-making, shaping Booking.com’s future.
• Offering opportunities for team members to explore new areas or specialize.
• Providing holistic, integrated legal and public affairs advice.
• Continuously improving Legal Operations, innovating, and sharing best practices.
• Learning from mistakes and embracing growth.
• Working collaboratively with a sense of humor and enjoying the journey together!

Benefits & Perks

Booking.com’s Total Rewards Philosophy is not only about compensation but also about benefits. We offer a competitive compensation and benefits package, as well unique-to-Booking.com benefits which include:

• Annual paid time off and generous paid leave scheme including: parent, grandparent, bereavement, and care leave.
• Hybrid working including flexible working arrangements, and up to 20 days per year working from abroad (home country).
• Industry leading product discounts - up to 1400 per year - for yourself, including automatic Genius Level 3 status and Booking.com wallet credit.