The
Financial Crimes Manager & CFT/AML Officer leads the Bank's enterprise
financial crimes compliance program, including Countering the Financing of Terrorism
and Anti-Money Laundering (CFT/AML), Bank Secrecy Act (BSA), Office of Foreign
Assets Control (OFAC), fraud risk coordination, and related regulatory
reporting. The position is responsible for establishing and maintaining
effective risk-based policies, controls, monitoring, investigations, training,
and governance; advising management and the Board of Directors; and ensuring
timely corrective action. This position is appointed by the Bank's Board of
Directors and approved annually.
Essential Duties and
Responsibilities (Other duties may be assigned.)
* Lead the Bank's enterprise financial crimes program and ensure compliance with applicable CFT/AML, BSA, USA PATRIOT Act, OFAC, and related financial crimes requirements across all business units.
Maintain and periodically update the Bank's
risk-based CFT/AML, BSA, OFAC, customer due diligence, suspicious activity
monitoring, and related financial crimes policies and procedures; ensure they
are understood and executed consistently across the Bank.
Conduct and document enterprise financial crimes
risk assessments, evaluate the design and effectiveness of controls, and
present annual assessments, mitigating factors, and significant residual risks
to the Audit Committee of the Board of Directors.
* Manage a team responsible for alert review,
customer investigations, enhanced due diligence, transaction monitoring,
sanctions screening, regulatory reporting, and ongoing monitoring of
higher-risk customers and activities.
* Oversee the accuracy, quality, documentation,
and timely submission of Currency Transaction Bs, Suspicious Activity Reports,
Designations of Exempt Person, and other required filings to FinCEN or other
governmental authorities.
* Coordinate with the Security Officer and other
stakeholders to identify, assess, investigate, and monitor fraud and other
financial crimes risks; determine whether suspicious activity reporting is
warranted and ensure decisions to file or not file are thoroughly documented.
* Respond to requests from law enforcement and
governmental authorities regarding suspicious activity, financial crimes
investigations, and regulatory filings.
* Supervise, coach, and direct Financial Crimes
Analysts, BSA/AML Analysts, investigators, and designated back-up personnel;
establish performance expectations, escalation protocols, quality standards,
and professional development plans.
* Serve as the senior internal subject-matter
expert for CFT/AML, BSA, OFAC, fraud, and related financial crimes matters,
advising banking offices, operations, lending, compliance, risk management, and
other departments.
* Maintain a role-based financial crimes training
program, including onboarding, periodic employee training, targeted remedial
training, and annual CFT/AML, BSA, OFAC, and financial crimes training for the
Board of Directors.
* Provide annual and interim reporting to the
Board of Directors and its committees regarding program effectiveness, key risk
indicators, significant investigations and filings, emerging threats, staffing,
systems, testing results, and corrective actions.
* Prepare and update the Financial Crimes staffing
and resource assessment at least annually, using appropriate risk, volume,
complexity, productivity, and service-level metrics.
* Maintain complete, accurate, and secure
case-management and referral records for suspicious activity, fraud, sanctions,
and other financial crimes matters. Maintain the Suspicious Activity Internal
Referral Spreadsheet (GAFFE) for tracking purposes. Support cross-functional efforts to identify,
assess, investigate, and mitigate fraud and other financial crimes risks.
* Serve as co-chair of the Bank's BSA/Compliance
Committee and coordinate enterprise reporting and escalation of material
financial crimes risks.
* Chair the SAR Committee and ensure consistent,
well-supported decisions, appropriate escalation, confidentiality, and timely
follow-through.
Champion the
Bank's financial crimes risk-management efforts by promoting a strong culture
of compliance, delivering training, and presenting risk trends and program
priorities to employees, management, committees, and the Board.
Monitor compliance and program effectiveness
through quality assurance, sampling, management information, trend analysis,
and control testing; escalate deficiencies and oversee timely corrective
action.
* Partner with Internal Audit, Compliance,
Enterprise Risk Management, Information Security, Legal, Operations, and
business leadership to identify and address financial crimes compliance risk.
* Remain current on changes in laws, regulations,
regulatory guidance, enforcement actions, typologies, sanctions, fraud trends,
products, delivery channels, and technologies that may affect the Bank's
financial crimes risk profile.
* Review new and revised products, services,
systems, customer segments, and delivery channels for financial crimes risk;
recommend appropriate controls before implementation.
* Serve as the lead contact for CFT/AML, BSA,
OFAC, and related financial crimes regulatory examinations, audits, and
independent testing; coordinate responses, remediation plans, and supporting
documentation.
* Bachelor's degree or a minimum of 5 to 7 years
of progressively responsible experience in CFT/AML, BSA, OFAC, fraud, financial
crimes investigations, or related banking compliance; or an equivalent
combination of education and experience.
* Prefer experience leading a financial crimes
compliance function, managing personnel, overseeing investigations and
regulatory filings, and interacting with executive management, directors,
auditors, regulators, and law enforcement.
* Strong written, verbal, and presentation skills,
with the ability to communicate complex risk, legal, and regulatory matters
clearly to diverse audiences, including the Board of Directors.
* Advanced analytical, investigative,
decision-making, and problem-solving skills, including the ability to evaluate
complex transactions, customer relationships, typologies, control gaps, and
competing risk considerations.
* Working knowledge of CFT/AML, BSA, OFAC,
customer identification, customer due diligence, beneficial ownership,
sanctions, information-sharing, suspicious activity reporting, fraud, and
financial crimes governance requirements.
* Proficiency with office productivity tools, data
analysis, case-management systems, transaction-monitoring systems,
sanctions-screening tools, and regulatory filing platforms.
* Strong organization, judgment, discretion, time
management, and attention to detail, with the ability to prioritize sensitive
matters and meet regulatory deadlines.
* Experience with financial crimes technology,
including Verafin and FIS Horizon, is preferred.
* Strong understanding of money laundering,
terrorist financing, sanctions evasion, fraud, cyber-enabled financial crime,
and other relevant typologies and controls.
Certificates, Licenses, Registrations
The following certifications are preferred:
- Certified Anti-Money Laundering
Specialist (CAMS)
- Certified Regulatory Compliance
Manager (CRCM) or other relevant financial crimes, compliance, fraud, or
risk-management certification