Bank Secrecy Act (BSA) Officer
New York, NY
Role Purpose (Overall high-level summary of the role)
- The Bank BSA Officer will lead the design and direction for the formulation, implementation and monitoring of the Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Assets Control (collectively " BSA/AML and OFAC ) compliance risk management program designed to ensure that the bank achieves optimum compliance with all BSA/AML and OFAC laws and regulations across all business lines.
- This role will lead/perform one or more activities to support the following:
- KYC: Customer Identification Program (CIP); Customer Due Diligence (CDD); and Enhanced Due Diligence (EDD).
- Currency Transaction Report (CTR).
- Suspicious activities monitoring and alert reviews and investigations on potential cases of money laundering, terrorist financing or other related financial crimes in compliance with applicable laws, regulations, guidance and BSA/AML/OFAC policies and procedures.
- OFAC Compliance.
- Develop and implement BSA/AML and OFAC related policies and procedures.
- Develop and implement BSA/AML and OFAC related training.
- Present to Board and senior management BSA/AML and OFAC related reports and key risk indicators.
Principal Accountabilities: Key activities and decision-making areas
- Develop and maintain a comprehensive compliance program to ensure ongoing compliance with the BSA/AML and OFAC laws and regulations;
- Monitor the level of compliance with BSA and related regulations throughout the business and conduct risk assessments of the effectiveness of bank compliance program;
- Conduct analysis of proposed BSA/AML and OFAC laws and regulations and associated emerging risks.
- Keep management informed and work with the General Counsel on the regulatory aspects that impact BSA risks for the Bank;
- Determine whether internal processes meet regulatory expectations, are functioning properly and accurately to identify risk and ensure compliance with policies, procedures and processes;
- Prepare the regulatory BSA examinations and internal audits;
- Prepare responses to exams and audits;
- Monitor compliance with the OFAC regulatory requirements;
- Conduct risk assessments to assure ongoing compliance with the BSA/AML and OFAC regulations;
- Monitor BSA/AML and OFAC training for all positions that require annual training;
- Evaluate, and when appropriate, recommend changes to policies and procedures of the Bank.
- Engages Chief Risk Officer and business management by providing formal reports regarding the evaluation of the effectiveness of control in relation to BSA/AML and OFAC compliance risk management program;
- Present risk assessment report to the Board of Directors and the management Compliance and BSA/AML and OFAC Committee; and
- Identify and report key BSA/AML and OFAC related MIS reports.
Leadership & Teamwork
- Work with senior executives to ensure compliance and BSA/AML and OFAC compliance standards are followed in each business unit. Oversight responsibilities to ensure control are maintained on a corporate-wide basis;
- Helps provide project management support on compliance-related projects and initiatives to ensure they progress toward a common goal in alignment with agreed timelines;
- Lead the identification of BSA/AML and OFAC Inherent risks and key risk indicators relevant to each line of business and business unit;
- Drives compliance excellence, consistency and quality across all business units;
- Collaborates and fosters good relations with all staff and business units; and
- Demonstrates core behaviors and values including teamwork, focus, drive and determination.
Operational Effectiveness & Control
- Establish compliance and BSA/AML and OFAC policies/procedures and ensures adherence to internal and external reporting standards, procedures and regulations;
- Identify compliance and BSA/AML and OFAC issues, provide recommendations and coordinate with the Chief Risk Officer on issues and sign-offs;
- Maintains a current knowledge of industry compliance initiatives pertaining to areas of responsibility and best practices;
- Work with the senior leadership team in supporting the implementation of compliance and BSA/AML and OFAC requirements, ensuring adequate compliance resources and training, fostering a compliance culture and optimizing relations with the regulators;
- Maintains awareness of major regulatory changes affecting assigned businesses; ensures appropriate communication and development of appropriate policy/procedure changes to remain compliant; and
- Complete other responsibilities as assigned.
Major Challenges (The challenges inherent in the role that require a continual test of the role holder's abilities)
- Shares ownership with business leadership team in the ongoing advancement of a positive compliance culture;
- Has a high level of engagement and awareness of activities across all business lines. Understands regulator's perspective on risk;
- Under and increasingly and heavily regulated environment, ensures the business lines are compliant with all applicable laws, rules and regulations;
- Operates effectively under the pressures of deadlines, constant regulatory oversight and business unit performance; and
- Maintenance of compliance stamina in a challenging start-up and ever-changing environment.
Role Context (The environment and operating conditions of the role including the context of guidance and authority)
- Sets priorities and makes day-to-day decisions independently;
- Escalates matters to senior management as needed;
- Works well independently, with minimal direction;
- Demonstrates a thorough understanding of policies and procedures pertaining to the role. Aware of what constitutes an effective control environment;
- Communicates effectively and professionally and conveys the key information needed to ensure compliance goal are met; and
- Actively engages with the Chief Risk Officer, as well as the senior leadership team.
Management of Risk (BSA/AML and OFAC risks and requirements)
- Ensure employees apply compliance and BSA/AML and OFAC controls in accordance with the Bank or regulatory standards, policies and procedures; and
- Physical Demands/Work Environment: very good working conditions. Little or no physical demands. Minimal handling of light materials. The physical demands/work environment described above are representative of those that must be met by an employee to successfully perform the essential duties of the job. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential duties.
Knowledge & Experience / Qualifications (For the role not the role holder. Minimum requirements of the role)
- Minimum of Bachelor's degree in business, related field or equivalent experience;
- A minimum of 7 to 10 years proven and progressive Commercial banking/ financial services operations, compliance and/or legal management experience or equivalent;
- Ideally, have previous experience with Fi-Serv;
- CAMS and Risk Management certification is desired, but not required;
- Comprehensive knowledge and experience in evaluating compliance, risk management
- A high degree of familiarity with BSA/AML and OFAC information technology concepts and applications in a wide range of operating environments;
- Strong verbal and written communication skills; ability to engage stakeholders to influence and effect change;
- Proven ability to prioritize competing demands;
- Deep understanding of regulatory reporting;
- Ability to form effective relationships and achieve influence at the most senior level in the organization;
- Experience managing internally and working with external vendors to execute a strong compliance risk management program;
- Sound judgment and strong analytical/problem-solving skill; and
- Strong project management skills; proven ability to manage project risks.