Requisition ID: 277181
Position: Director, Counterparty Credit Risk, Latin America (LATAM) Lead, Global Risk Management
Purpose
The Counterparty Credit Risk - LATAM Lead will provide regional leadership and independent second-line oversight of Counterparty Credit Risk (CCR) across Latin America. The role will be responsible for establishing a consistent, comprehensive and sustainable CCR framework across LATAM while ensuring appropriate recognition of local regulatory, legal, market and business requirements.
The role will serve as the principal regional point of coordination between Global CCR, local CCR and Risk teams, Credit Officers, Legal, business lines and other control functions. The position will translate global CCR standards into effective local execution and ensure that emerging regional considerations are appropriately reflected in the global framework. This aligns with the proposed LATAM model of a single regional CCR owner with functional accountability to Global CCR and close connectivity with local risk teams.
Accountabilities
• Champions a customer focused culture to deepen client relationships and leverage broader Bank relationships, systems and knowledge.
• Regional CCR leadership and governance: Lead the LATAM CCR agenda and coordinate activities across local CCR and Risk teams, establishing clear ownership, escalation and governance. Drive consistent application of global CCR policies, methodologies, metrics and standards while accommodating legitimate local regulatory requirements.
• CCR framework development: Build out and continuously enhance the regional CCR framework covering derivatives, Securities Financing Transactions (SFTs), margin lending and other activities generating counterparty exposure. Ensure appropriate coverage of exposure measurement, PFE, collateral, concentrations, wrong-way risk, limits and escalation. These areas are consistent with the Bank's broader CCR framework.
• Risk appetite and limits: Partner with Credit Officers and Global CCR to establish and maintain appropriate regional and country-level risk appetite, limits and escalation thresholds. Provide independent challenge regarding concentrations, counterparties, products and business proposals. The existing framework provides for ongoing monitoring and remedial action as exposures approach or exceed risk appetite.
• Stress testing: Establish and oversee a comprehensive LATAM CCR stress-testing program, including appropriate coverage of material counterparties, products, concentrations and country-specific vulnerabilities. Ensure consistency with the global stress framework while incorporating LATAM-specific risk factors and scenarios. Stress testing is a core component of the existing CCR framework and supports concentration and wrong-way-risk monitoring.
• Legal documentation and terms: Partner with Legal, Credit and the business to drive standardization of counterparty credit terms, including collateral, margin, netting, termination and other material credit provisions. Establish governance for exceptions and ensure non-standard terms receive appropriate independent risk review. The current CCR framework specifically provides for Credit review of non-standard trade documentation and approval in conjunction with Legal and trading management.
• Business growth and new initiatives: Provide CCR oversight and constructive challenge for growth initiatives across LATAM, ensuring new products, markets and counterparties have appropriate risk appetite, limits, documentation, stress testing, data and controls before launch. This is particularly relevant as current LATAM initiatives include expansion of emerging-market financing and structured products.
• Regulatory oversight: Monitor the evolving regulatory environment across LATAM jurisdictions and assess its implications for CCR. Coordinate implementation of regulatory requirements and maintain appropriate evidence, governance and issue tracking. The proposed regional operating model specifically identifies country-level regulatory readiness as an enduring responsibility of the LATAM CCR Head.
• Portfolio oversight: Maintain an integrated view of the LATAM CCR portfolio, including exposures, concentrations, collateral, stress results, limit utilization, exceptions and emerging risks. Identify potential deterioration or concentrations early and coordinate appropriate mitigation and escalation.
• Global consistency and local implementation: Drive convergence toward common global methodologies, policies, data standards, reporting and governance while ensuring local requirements remain appropriately addressed. Current internal work identifies incomplete LATAM coverage and an undefined regional monitoring/reporting RACI as issues requiring remediation.
• Data, infrastructure and controls: Partner with Technology, Analytics, Operations and local teams to improve completeness and quality of regional CCR data and ensure LATAM activity is appropriately incorporated into global monitoring and reporting infrastructure. Internal work has specifically identified locally booked LATAM activity and International Banking SFT exposure as areas requiring fuller enterprise integration.
The Head / Director, AML Investigations is a senior leadership role accountable for the design, execution, and continuous improvement of the institution's AML Investigations and client EDD program. The role holder serves as the institution's primary decision-making authority across alert adjudication, complex case investigation, SAR filing, and risk-based enhanced due diligence for higher-risk customer segments - ensuring these functions operate as an integrated, intelligence-led program rather than discrete compliance activities.
Accountabilities
AML Investigations Leadership & Alert Management
• Provide strategic and operational oversight of the full alert lifecycle, from transaction monitoring and name-screening triage through investigation, disposition, and escalation, ensuring quality, timeliness, and consistency across all queues and detection typologies
• Establish and own SLAs, KPIs, and quality assurance frameworks governing alert adjudication, case aging, SAR filing timelines, and investigator output; present performance metrics and emerging trend intelligence to senior management and relevant governance committees on a defined cadence
• Direct the institution's SAR program, setting and enforcing narrative quality standards, timely filing with FinCEN in accordance with 31 CFR Part 1020, and maintaining defensible documentation standards across all filing decisions consistent with FRBNY and NYDFS supervisory expectations
• Manage and respond to all law enforcement requests within the AML Investigations remit, including FinCEN Section 314(a)/(b) inquiries, Grand Jury subpoenas, and National Security Letters, ensuring accurate, timely, and well-documented responses
• Partner with Technology, Model Risk, and Compliance teams to drive continuous tuning of transaction monitoring scenarios, entity resolution, and alert scoring capabilities, reducing false-positive rates and enhancing detection coverage aligned to the institution's evolving risk profile and NYDFS Part 504 model validation requirements
AML Case Management & Complex Investigations
• Lead and directly supervise a team of senior AML investigators responsible for conducting complex, high-risk, and multi-jurisdictional investigations involving money laundering, terrorist financing, sanctions evasion, fraud nexus typologies, and other designated financial crime risks
• Establish and maintain investigation methodologies, case workflow standards, escalation protocols, and documentation requirements to ensure all investigative decisions are well-reasoned, evidence-based, and examination-ready for review by FRBNY, NYDFS, FRBT, and TDB
• Serve as the ultimate internal decision-making authority on SAR filing determinations for sensitive, high-profile, or materially complex matters, including cases involving PEPs, significant customer relationships, senior management, or potential reputational exposure
• Ensure investigative intelligence - including typology findings, behavioral patterns, and emerging red flags - is systematically fed back into the enterprise AML/CFT risk assessment, customer risk scoring models, and detection scenario libraries
• Oversee the triage and escalation of cases involving elevated complexity, including those touching high-risk jurisdictions, correspondent banking channels, virtual asset activity, trade-based money laundering, block trading, and PSP/MVTS exposures
Client Enhanced Due Diligence Program
• Own and lead the institution's Enhanced Due Diligence program for designated higher-risk customer segments, including Politically Exposed Persons (PEPs), Money Services Businesses (MSBs), Payment Service Providers (PSPs), foreign financial institutions, cannabis-related businesses, Non-Governmental Organizations (NGOs), and other segments as defined by the risk appetite framework
• Develop, maintain, and continuously improve risk-tiered EDD procedures, documentation standards, and review checklists for each high-risk segment, ensuring alignment with FinCEN CDD/EDD guidance, FATF Recommendations, and supervisory expectations of the FRBNY, NYDFS, FRBT, and TDB
• Oversee the critical assessment and validation of Source of Funds (SOF) and Source of Wealth (SOW) documentation for high-risk clients, ensuring evidence-based conclusions are reached, challenged where warranted, and documented to a fully defensible standard
• Establish and manage a structured periodic review program for high-risk client files, including trigger-based and event-driven reviews, with clear ownership, escalation paths, and remediation timelines for documentation deficiencies or material risk changes
• Integrate EDD intelligence with AML Investigations investigative activities to maintain a unified, holistic view of client risk, ensuring that EDD findings drive investigative escalation where warranted, and that SAR-related intelligence informs EDD review prioritization
Policy, Governance & Regulatory Management
• Develop, implement, and maintain all AML Investigations and EDD-related policies, procedures, and program standards, ensuring ongoing alignment with regulatory requirements, FinCEN advisories, FATF guidance, NYDFS Part 504 obligations, and internal risk appetite statements
• Serve as the institution's subject matter expert and primary point of contact during regulatory examinations and supervisory interactions conducted by the FRBNY, NYDFS, FRBT, TDB, and FinCEN on all matters within the AML Investigations and high-risk client management domains; own the preparation, coordination, and presentation of all relevant program documentation and examination responses
• Proactively develop and maintain strong working relationships with FRBNY, NYDFS, FRBT, and TDB examination teams, ensuring the institution is well-positioned ahead of scheduled and targeted supervisory reviews
• Coordinate and respond to Internal Audit reviews related to AML Investigations and EDD, develop comprehensive corrective action plans and track remediation activities through sustainable closure
• Monitor regulatory, legislative, and enforcement developments - including FinCEN advisories, DOJ and OFAC enforcement actions, NYDFS consent order trends, FATF mutual evaluation outcomes, and FRBT policy guidance - and translate these into timely, actionable program enhancements
Technology, Analytics & Intelligence
• Champion the adoption of advanced analytics, AI-assisted alert scoring, network link analysis, and entity resolution capabilities to elevate detection of complex ML/TF patterns and enhance investigator efficiency
• Partner with Technology and Vendor Management on the performance oversight and optimization of transaction monitoring, name-screening, and case management platforms, ensuring tools remain operationally effective and defensible under FRBNY and NYDFS supervisory scrutiny
• Develop and maintain a management information and reporting framework that delivers actionable insight into investigative trends, EDD portfolio risk concentrations, SAR filing patterns, and typology intelligence to senior leadership and governance forums
People Leadership & Culture
• Build, lead, and retain a high-performing team of AML investigators, case managers, and EDD analysts; establish clear role expectations, performance accountability, career development frameworks, and succession plans across the combined function
• Design and deliver targeted training programs covering investigative methodologies, SAR narrative quality, EDD documentation standards, emerging typologies, and current regulatory expectations including those specific to NYDFS, FRBNY, and TDB examination priorities
• Foster a culture of intellectual rigor, sound judgment, accountability, and continuous improvement across the integrated investigations and EDD function
• Identify and implement structured cross-training pathways between investigative and EDD teams to develop
