Position SummaryTheFinancial Crimes Manager & CFT/AML Officer leads the Bank's enterprisefinancial crimes compliance program, including Countering the Financing of Terrorismand Anti-Money Laundering (CFT/AML), Bank Secrecy Act (BSA), Office of ForeignAssets Control (OFAC), fraud risk coordination, and related regulatoryreporting. The position is responsible for establishing and maintainingeffective risk-based policies, controls, monitoring, investigations, training,and governance; advising management and the Board of Directors; and ensuringtimely corrective action. This position is appointed by the Bank's Board ofDirectors and approved annually.
Essential Duties andResponsibilities (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'srisk-based CFT/AML, BSA, OFAC, customer due diligence, suspicious activitymonitoring, and related financial crimes policies and procedures; ensure theyare understood and executed consistently across the Bank.
Conduct and document enterprise financial crimesrisk assessments, evaluate the design and effectiveness of controls, andpresent annual assessments, mitigating factors, and significant residual risksto 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 ofhigher-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 othergovernmental authorities.
• Coordinate with the Security Officer and otherstakeholders to identify, assess, investigate, and monitor fraud and otherfinancial crimes risks; determine whether suspicious activity reporting iswarranted and ensure decisions to file or not file are thoroughly documented.
• Respond to requests from law enforcement andgovernmental authorities regarding suspicious activity, financial crimesinvestigations, and regulatory filings.
• Supervise, coach, and direct Financial CrimesAnalysts, 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-matterexpert for CFT/AML, BSA, OFAC, fraud, and related financial crimes matters,advising banking offices, operations, lending, compliance, risk management, andother departments.
• Maintain a role-based financial crimes trainingprogram, including onboarding, periodic employee training, targeted remedialtraining, and annual CFT/AML, BSA, OFAC, and financial crimes training for theBoard of Directors.
• Provide annual and interim reporting to theBoard of Directors and its committees regarding program effectiveness, key riskindicators, significant investigations and filings, emerging threats, staffing,systems, testing results, and corrective actions.
• Prepare and update the Financial Crimes staffingand resource assessment at least annually, using appropriate risk, volume,complexity, productivity, and service-level metrics.
• Maintain complete, accurate, and securecase-management and referral records for suspicious activity, fraud, sanctions,and other financial crimes matters. Maintain the Suspicious Activity InternalReferral 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/ComplianceCommittee and coordinate enterprise reporting and escalation of materialfinancial crimes risks.
• Chair the SAR Committee and ensure consistent,well-supported decisions, appropriate escalation, confidentiality, and timelyfollow-through.
Champion theBank's financial crimes risk-management efforts by promoting a strong cultureof compliance, delivering training, and presenting risk trends and programpriorities to employees, management, committees, and the Board.
Monitor compliance and program effectivenessthrough quality assurance, sampling, management information, trend analysis,and control testing; escalate deficiencies and oversee timely correctiveaction.
• Partner with Internal Audit, Compliance,Enterprise Risk Management, Information Security, Legal, Operations, andbusiness 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'sfinancial 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, andindependent testing; coordinate responses, remediation plans, and supportingdocumentation.
Qualifications• Bachelor's degree or a minimum of 5 to 7 yearsof progressively responsible experience in CFT/AML, BSA, OFAC, fraud, financialcrimes investigations, or related banking compliance; or an equivalentcombination of education and experience.
• Prefer experience leading a financial crimescompliance function, managing personnel, overseeing investigations andregulatory 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 mattersclearly to diverse audiences, including the Board of Directors.
• Advanced analytical, investigative,decision-making, and problem-solving skills, including the ability to evaluatecomplex transactions, customer relationships, typologies, control gaps, andcompeting risk considerations.
• Working knowledge of CFT/AML, BSA, OFAC,customer identification, customer due diligence, beneficial ownership,sanctions, information-sharing, suspicious activity reporting, fraud, andfinancial crimes governance requirements.
• Proficiency with office productivity tools, dataanalysis, case-management systems, transaction-monitoring systems,sanctions-screening tools, and regulatory filing platforms.
• Strong organization, judgment, discretion, timemanagement, and attention to detail, with the ability to prioritize sensitivematters 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, RegistrationsThe following certifications are preferred:
- Certified Anti-Money LaunderingSpecialist (CAMS)
- Certified Regulatory ComplianceManager (CRCM) or other relevant financial crimes, compliance, fraud, orrisk-management certification
