The incumbent is responsible for administering the ongoing development and review of Associated's BSA/AML/OFAC risk management program in accordance with all regulatory requirements under the Bank Secrecy Act, USA Patriot Act, OFAC and other Anti-Money Laundering laws and regulations. The incumbent is responsible for conducting the BSA/AML and OFAC risk assessments for Associated Business Lines and bank affiliates, managing quarterly reviews of the BSA program, and recommending revisions to the Bank's BSA/AML Program resulting from changes in the Bank's risk profile or industry information.
In addition, this position is responsible for drafting and supporting policies and procedures for BSA/AML/OFAC compliance, completing an annual gap assessment, providing support for the coverage assessment, and maintaining the organization's CDD accountability, NAICS code quality assurance, correspondent banking questionnaires both upstream and downstream, and CIP processes.
The Enhanced Due Diligence (EDD) team will also report into this position. The incumbent will be responsible to ensure that all areas of Customer due diligence and Enhanced due diligence are appropriate and compliant including customer risk model, CDD / EDD policies and ongoing production support of the EDD team efforts. This role will be an escalation point for customer reviews and retention decisions and will be key in the remedial action process.
Finally, this position will assist with leadership and ongoing oversight and review of the regulatory climate and provide overall guidance to ensure adequate risk mitigation as well as provide appropriate mentorship and training of the Financial Intelligence team. This will include acting as a back-up and proxy for the BSA Officer for certain tasks and projects.
Operates in full compliance with internal policies and procedures as well as applicable regulations and laws, including but not limited to Bank Secrecy Act/Anti-Money Laundering requirements. Responsible to report any procedure or process that doesn’t meet regulatory requirements including fraud, whether suspected or confirmed, to management. This reporting can be done directly to any member of management, including Human Resources or Corporate Security, or can be reported through Associated’s anonymous Ethics Hotline.
KEY RESULT AREAS
Regulation and Compliance
Lead Risk Assessment team and work with the Business Lines and bank affiliates to facilitate Associated’s BSA/AML/OFAC risk management program which includes the development, implementation, and revision of BSA, Fraud, and OFAC risk assessments.
Act as back up to the BSA, AML, OFAC officer and provide guidance and mentorship across all FID. Assist with audit and regulatory reviews.
Provide for a quarterly risk review process, review data, provide feedback and insight, and recommend changes as necessary for risk mitigation.
Advise FID and LOB management on regulatory implications of new products and processes. Act as escalation point and key contributor in FID compliance decisions
Interpret laws and federal banking regulations and evaluate established BSA/AML and OFAC procedures, processes, forms and internal controls throughout the organization in relation to regulatory requirements to determine design effectiveness, identify areas for enhancement and ensure appropriate compliance and risk mitigation.
Manage the OFAC team to ensure appropriate and compliant coverage with all screening and sanctions compliance.
Create or modify policies, procedures, forms and internal controls as requested or required to ensure appropriate coverage and compliance across FID.
Maintain the enterprise-wide Customer Identification Program including required identifying information, verification and exception processes. Act as escalation point for CIP questions and controls.
Communicate policy/procedure/form updates, accountability reporting, risk assessment results, gaps, enhancements, and proposed solutions to applicable senior management, risk personnel, Internal Audit, compliance, etc., as necessary.
Support the gap analysis, coverage assessment, high risk country model, HIDTA and HIFCA review, disaster recovery plan, FID training, colleague certification tracking, model validation and audit review.
Assist management in special projects, reports, training and/or presentations to communicate program updates.
Manage the EDD team to ensure appropriate and compliant coverage with the customer risk model, CDD and EDD policies, and ongoing enhanced due diligence production support
Recommend enhancements to ensure maximum effectiveness, increased efficiencies and ongoing fully compliant support across FID.
Bachelor's Degree or equivalent combination of education and experience in BSA/AML, Financial Intelligence, banking, compliance or audit. Required
4-7 years BSA/AML, banking, compliance or audit related experience. Required
7-10 years BSA/AML security, banking, compliance, Audit, account monitoring experience or related experience. Preferred
LICENSES & CERTIFICATIONS
CAMS-Certified Anti-Money Laundering Specialist within 1 year Required