SUMMARY This position is responsible for establishing, managing and administering the BSA/AML programs, policies and procedures. Reports directly to the Audit Committee and participates with other senior management members in the assessment and implementation of Sunwest Bank's (Bank) BSA Program.
ESSENTIAL DUTIES AND RESPONSIBILITIES- Review and update Program & Risk Assessment annually
- Coordinate, communicate and monitor day-to-day BSA compliance through the management of department processes and team members
- Manage all aspects of the BSA compliance program including adherence to the BSA and its regulations
- Carry out the direction of the Board and ensure that employees adhere to the Bank's BSA policies and procedures
- Manage or review the daily OFAC Activity Reports
- Review SACR reports with Senior BSA Analyst to determine if a SAR filing is warranted
- Review monthly Patriot Officer AML monitoring reports (SAR Detector, Money Transfer monitoring, CIP Missing Data Report and Risk Management) for AML activity.
- Prepare quarterly department staff meetings
- Review EDDs on high and medium risk accounts submitted by BSA Analyst team members
- Review all BSA-related SARs submitted to FinCEN
- Review and approve all "No File SAR" reports whenever warranted
- Notify the Board (or their designated committee) monthly of SARs filed for the month
- Provide regular updates, reports and program status to Executive Management and the Audit Committee
- Retain electronically submitted SARs and CTRs
- Process all 314(a) Information Searches; this procedure is inspected by annual external internal audit verification and reported to the Audit Committee
- Review and maintain list of CTR exemptions
- Hold periodic SAR Committee meetings with management to escalate significant or repeat SARs for review
- Additionally, the BSA Officer is expected to know and follow the Bank's compliance policies and procedures as required by the Compliance Department, including but not limited to:
- Expedited Funds Availability (Regulation CC)
- Duties include providing proper disclosures at account opening and making funds deposited into accounts available for withdrawal in compliance with the regulation and Sunwest Bank's policies and procedures
- Truth in Savings (Regulation DD)
- Duties include providing accurate disclosures at account opening and upon request in compliance with the Bank's policy
- Regulation D
- Duties include understanding of NOW account eligibility, MMDA and savings account transfer restrictions, and early withdrawal penalties
- Electronic Funds Transfers
- Duties include providing proper disclosures at account opening, knowledge of the proper handling of errors reported and knowledge of restrictions on fees
- Regulation O
- Duties include knowledge of the types of transaction restrictions for Directors and Executive Officers
- Elder and Dependent Adult Financial Abuse
- Duties include recognition and proper reporting of Elder and Dependent Adult Financial Abuse
- Consumer Complaints
- Duties include knowledge of the definition of a consumer complaint and Sunwest Bank's policies and reporting responsibilities
- Privacy (Regulation P)
- Duties include providing proper disclosures at account opening and securing non-public personal information of consumers and customers of Sunwest Bank
- Identity Theft (Fair Credit Reporting Act)
- Duties include knowledge of the proper reporting of suspected identity theft and the proper completion of address changes. Thorough understanding of the Bank's responsibilities to detect, prevent and mitigate losses due to identity theft
- Advertising
- Duties include knowledge of the proper procedure for all types of advertising including proper Senior Management and Compliance approval for all promotions
- Unfair or Deceptive Acts or Practices
- Duties include knowledge of Sunwest Bank's commitment to clearly disclose products and services to the public
ADDITIONAL RESPONSIBILITIES- Demonstrates high degree of professionalism in communication, attitude and teamwork with customers, peers and management
- Demonstrates high level of quality work, attendance and appearance
- Adheres to all Company Policies & Procedures and Safety Regulations
- Adheres to local, state and federal laws
- Understands and complies with all company rules and regulations
- Attends training and maintains a basic knowledge of procedures to ensure compliance with laws and regulations governing financial institutions, as they apply to your position and job responsibilities, with an emphasis on the BSA/AML/CIP, Consumer Privacy, Regulation CC, Information Security, Bank Protection Act, FACT-Identity Theft, Information Technology and GLBA.
- Additional duties as assigned as it relates to the position
SUPERVISORY RESPONSIBILITIESThis position does have supervisory responsibilities
MINIMUM QUALIFICATIONS- Minimum of ten years of recent experience working in related BSA/AML position
- Minimum of 3-5 years of recent management experience
- Must possess outstanding current knowledge of banking regulations (CDFI, FDIC, FFIEC)
- Excellent level of problem solving capabilities to establish potential alternatives and solutions to problems
- Excellent communication orally and in writing. Ability to work with all levels of management
- Must be highly organized and capable of handling multiple tasks concurrently, be able to redirect priorities based upon current workload (ability to react to current situations)
- Excellent knowledge of banking products, particularly those offered in business banking environment
- Experience with FiServ or other major core and reporting applications is desired
COMPETENCIES:- Adaptability
- Communication
- Decision Making
- Initiative
- Innovation
- Motivator
- Organization
- Professionalism
- Results Orientated
