Senior Director Compliance

The Senior Director Compliance will serve as MoonLake's senior internal compliance leader and the day-to-day owner of the United States compliance program. This is a build role rather than a maintenance role. MoonLake has no approved product currently on the market, and the successful candidate will be designing and implementing a scalable, risk-based compliance framework, policies, processes, forms, tools, training, monitoring, and transparency reporting, and embedding them in a lean and fast-moving organization before the first commercial interaction occurs.
The role will lead and operationalize MoonLake´s compliance framework across its United States operations and, where relevant, its European and Swiss activities. Key areas of responsibility include US healthcare fraud and abuse laws, including the Federal Anti-Kickback Statute and the False Claims Act; the Federal Food, Drug, and Cosmetic Act and FDA advertising and promotion requirements, including the restrictions that apply to a company with no approved product; federal and state transparency and aggregate spend reporting; federal exclusion and debarment screening; the United States Foreign Corrupt Practices Act; the EFPIA Disclosure Code and applicable national codes to the extent MoonLake's activities have European reach; the revised Swiss Federal Act on Data Protection and the EU General Data Protection Regulation as they apply to MoonLake's operations. In addition, the role will champion MoonLake's Code of Conduct and compliance policies, translating regulatory requirements into practical, risk-based controls that support the Company´s growth, launch readiness and culture of integrity.
Consistent with the OIG's 2003 Compliance Program Guidance for Pharmaceutical Manufacturers and the OIG's 2023 General Compliance Program Guidance, the successful candidate will operationalize and continuously improve an effective program built around the seven elements, scaled appropriately for a launch-stage company of MoonLake's size, geographic reach, and risk profile.
MoonLake currently receives compliance leadership on a fractional basis. The successful candidate will work alongside that resource during onboarding, will assume day-to-day ownership of the program, and is expected to become the company's permanent internal compliance lead.


Key Accountabilities

Program build-out and governance

1. Lead the implementation, own the execution and continuous improvement of MoonLake's United States compliance program, including the Code of Conduct, the compliance policy suite, and supporting standard operating procedures.
2. Complete and assume ownership of the compliance policy build-out already in progress, including the non-promotional activities, advisory board, HCP engagement, patient advocacy and patient interaction, payer interaction, meals and hospitality, HCP travel and expense, medical legal and regulatory review, and speaker program policies, together with the Needs Assessment Form, the Fair Market Value Rate Matrix and tiering tool, and the HCP master agreement and activity statements of work.
3. Deliver the promotional and commercial policy set ahead of approval and launch, ensuring organizational readiness across promotion, promotional speaker programs and the speaker bureau, congress and exhibits, personal services, samples, field interactions, social media, managed markets and contracting, and copay and patient support programs.
4. Support the Compliance Committee. Develop agendas, document deliberations , and prepare quarterly reporting to executive leadership and to the Board on program effectiveness, risks identified, and remediation status.
5. Own a documented policy lifecycle, including version control, a periodic review cadence, named policy owners, and a change log, and maintain consistent defined terms and cross references across the policy suite.
6. Establish and maintain MoonLake´s compliance with state comprehensive compliance program statutes, including California Health and Safety Code sections 119400 to 119402, and prepare the annual written declarations of compliance.

Pre-approval and launch readiness

1. Own the pre-approval compliance posture. Ensure that no communication represents an investigational product as safe or effective, that disease-state and scientific exchange activity remains non-promotional, and that the Company´s pre-launch activities do not constitute premature commercialization
2. Advise on and govern the deployment of a pre-approval field organization, including the conduct guardrails that apply, the boundary between permitted disease-state education and impermissible promotion, escalation to Medical Information, and the transition of personnel into commercial roles upon approval.
3. Govern pre-approval information exchange with payers and population health decision makers, and ensure that communications remain factual, balanced, and within the applicable framework.
4. Build launch readiness against a defined timeline, so that policies, training, monitoring, aggregate spend capture, and transparency reporting are operational before the first commercial interaction rather than after it.
5. Advise on patient support program design, including bridge and patient assistance program structures, copay assistance, free goods, and hub and specialty pharmacy arrangements, and the government payer considerations that constrain each.

Interactions with healthcare professionals and fraud and abuse compliance

1. Oversee compliance with the Federal Anti-Kickback Statute, the False Claims Act, and applicable OIG guidance, including the 2020 Special Fraud Alert on speaker programs, governing all interactions with healthcare professionals.
2. Own the fair market value framework, including the tiered rate matrix, the tiering tool and its criteria, written agreements, needs assessments, and engagement caps for speaker, consultant, and advisory board arrangements.
3. Maintain a tiering methodology that weights community and academic practice equally, so that expertise resident in private and community practice is recognized and compensated on a defensible basis.
4. Require that transfers of value be pre-approved through Compliance, maintaining clear separation from commercial decision-making
5. Maintain meal, travel, and hospitality limits aligned to internal caps and to the strictest applicable state requirements, and enforce the prohibition on company-funded alcohol at programs.
6. Monitor state gift ban, marketing limitation, and aggregate spend laws, including those of California, Connecticut, Massachusetts, Minnesota, Nevada, and Vermont, and manage state representative licensure and registration obligations.

Material review, advertising, and promotion

1. Serve as the standing Compliance member of the medical, legal, and regulatory review committee, and operate the tiered risk-based review process, its service levels, and the material lifecycle from approval through expiry and withdrawal.
2. Ensure that promotional and non-promotional materials are reviewed against FDA, OIG, and FTC requirements and, where applicable, national code requirements.
3. Require mandatory re-review of materials upon labeling, safety, or data updates, and maintain a defined withdrawal and recall procedure.
4. Own the compliance perspective on the selection and configuration of material review technology, including any automated or artificial-intelligence-assisted review, and enforce the requirement that a named human reviewer records every approval.

Risk assessment, monitoring, and auditing

1. Conduct and lead an annual enterprise compliance risk assessment covering United States operations and any activity with European or Swiss reach, and translate the results into a prioritized workplan.
2. Build and execute a risk-based monitoring plan covering field activity, speaker and disease-state programs, advisory boards, patient support activity, grants and sponsorships, and third-party intermediaries.
3. Establish the monitoring program ahead of launch and the audit program thereafter, including sampling methodology, evidence retention, and documented closure of findings.
4. Document findings, agreed corrective and preventive actions, and effectiveness verification, and track remediation to completion against defined timelines.

Transparency reporting and aggregate spend

1. Capture transfers of value from the first engagement, so that MoonLake's records are launch-ready rather than reconstructed.
2. Select and implement the aggregate spend and transparency reporting solution, and own the vendor relationship and the underlying processes.
3. Own the end-to-end Federal Open Payments process for all covered recipients, including annual data collection, validation, dispute resolution, submission to CMS, and recordkeeping, and own all state aggregate spend filings.
4. Coordinate European transparency disclosure under the EFPIA Disclosure Code and applicable national codes to the extent MoonLake's activities require it.

Screening, third parties, and anti-corruption

1. Maintain monthly screening of employees, contractors, vendors, healthcare professionals, and speakers against the OIG List of Excluded Individuals and Entities, the GSA System for Award Management, and the FDA Debarment List, with documented evidence and defined remediation procedures.
2. Maintain the third-party intermediary program, including risk-based due diligence, written approvals, contractual anti-corruption undertakings, training, and periodic re-assessment.
3. Maintain and enforce the anti-bribery and anti-corruption program under the United States Foreign Corrupt Practices Act and applicable Swiss and European requirements.

Training, investigations, and reporting channels

1. Design and deliver risk-based compliance training, including new hire, annual refresher, role-specific, and event-driven training, and track completion, effectiveness, and signed attestations.
2. Stand up and maintain the training record system, and report completion to leadership with an escalation path for non-completion.
3. Implement and own the confidential and anonymous compliance reporting hotline and other reporting channels, operationalize non-retaliation, and analyze and report on report trends.
4. Lead investigations of compliance allegations, coordinate with Legal, HR People & Culture, and outside counsel as appropriate. Document findings, root causes and corrective actions, and apply consistent and well-publicized disciplinary standards, in accordance with MoonLake´s governance framework and internal policies.
5. Serve as a point of contact for the FDA, OIG, DOJ, CMS, and state regulators on compliance matters, and coordinate response strategy with Legal and outside counsel.

Data protection interface

1. Partner with Legal, Information Technology, and the Data Protection Officer on the compliance-adjacent aspects of data protection, including patient authorization, the handling of protected health information by field and patient-facing personnel, and the data flows arising from hub, specialty pharmacy, copay, and data aggregation arrangements.
2. Ensure that the United States data protection posture is built for United States requirements, and coordinate with the Swiss and European privacy workstream rather than importing requirements that do not apply.

Culture

1. Promote a speak-up culture across every function, and act as a visible, approachable, and practical business partner. Compliance at MoonLake is a governance function that identifies, analyzes, and mitigates risk; it is not an approving function for business decisions, and it is not a check-the-box exercise.