BSA AML Policy & Governance Team Lead

GENERAL DESCRIPTION OF POSITION

The AML Policy & Governance Lead will be responsible for assisting in the efforts of developing, enhancing, and maintaining a number of governance related tasks such as the enterprise-wide BSA/AML and Office of Foreign Assets Control (OFAC) risk assessments; Enterprise AML Groups Department policies and programs, procedures, and other controls based on regulatory/policy changes, risk assessment results, audit and exam findings; etc.

The AML Policy & Governance Lead will evaluate and execute new BSA/AML, OFAC, or other regulatory changes, guidance, and industry best practices against the existing Compliance program, such as the AML Act of 2020. The AML Policy & Governance Lead will also support the other Enterprise AML Group Department teams in developing, enhancing, and executing upon control and process improvements, as well as, assist with other projects impacting the Department. May also participate in special AML Compliance reviews, projects and training efforts, as required. This specialist must have a solid understanding of all related laws and regulatory requirements as it relates to BSA/AML and OFAC.

Ideal Candidate must have a risk-based and innovative mindset, while also the ability to work collaboratively with other Enterprise AML Department managers and other internal stakeholders to influence change.

ESSENTIAL DUTIES AND RESPONSIBILITIES

1. Assist in drafting, enhancing, and maintaining Enterprise BSA/AML policies, procedures, and supporting documentation. This duty is performed annually, about 20% of the time.

2. Review requested policy exceptions and determine mitigation factors needed to maintain customer relationships, products, or services. Draft documentation to be submitted to BSA Committee. This duty is performed quarterly, about 10% of the time.

3. Draft, enhance, and maintain of the enterprise-wide BSA/AML and OFAC training program. This duty is performed annually, about 10% of the time.

4. Develop, enhance, verify, and maintain LOB Risk Assessment Surveys to assists LOBs identify emerging BSA/AML and OFAC risks. This duty is performed quarterly, about 10% of the time.

5. Research and assess BSA/AML and OFAC risk in current and new bank initiatives while providing easy to understand guidance to business staff and senior management. Draft findings and recommend plan of action. This duty is performed as needed, about 10% of the time.

6. Assist in coordinating BSA/AML and OFAC internal audits, regulatory examination, and other testing processes. This duty is performed as needed, about 10% of the time.

7. Serve as an advisor and subject matter expert to BSA/AML and OFAC staff, Bank employees, the Board, Senior Management, etc., of emerging issues, policy, and interpretation of regulations. This duty is performed as needed, about 10% of the time.

8. Monitor and stay current with BSA/AML and OFAC regulatory, industry developments, and best practices. Provide an impact analysis on new and amended laws, regulations, and regulatory guidance. This duty is performed as needed, about 10% of the time.

9. Attend compliance related meetings with business partners at the various bank regions, as applicable, in relation to the Enterprise BSA/AML Compliance Program. This duty is performed as needed, about 10% of the time.

10. Monitor and oversee quarterly BSA/AML and OFAC training completions and track unfinished assignments. This duty is performed as needed.

11. Completes required BSA/AML training and other compliance training as assigned. This duty is performed quarterly, about 10% of the time.

12. The ability to work in a constant state of alertness and in a safe manner. This duty is performed daily.

13. Perform any other related duties as required or assigned.

QUALIFICATIONS

To perform this job successfully, an individual must be able to perform each essential duty mentioned satisfactorily. The requirements listed below are representative of the knowledge, skill, and/or ability required.

EDUCATION AND EXPERIENCE

Broad knowledge of such fields as accounting, marketing, business administration, finance, etc. Equivalent to a four year college degree, plus 5 years related experience and/or training, and 12 to 18 months related management experience, or equivalent combination of education and experience.

COMMUNICATION SKILLS

Ability to write reports, business correspondence, and policy/procedure manuals; ability to effectively present information and respond to questions from groups of managers, clients, customers, and the general public. ability to read, analyze, and understand common scientific and technical journals, financial reports, and legal documents; ability to respond to complex or difficult inquiries or complaints from customers, regulatory agencies, or members of the business community.

MATHEMATICAL SKILLS

Ability to calculate figures and amounts such as discounts, interest, commissions, proportions, percentages, area, circumference, and volume. Ability to apply concepts such as fractions, ratios, and proportions to practical situations.

CRITICAL THINKING SKILLS

Ability to solve practical problems and deal with a variety of known variables in situations where only limited standardization exists. Ability to interpret a variety of instructions furnished in written, oral, or diagram formats.

REQUIRED CERTIFICATES, LICENSES, REGISTRATIONS

Not indicated.

PREFERRED CERTIFICATES, LICENSES, REGISTRATIONS

Certified Anti-Money Laundering Specialist (CAMS) Certification, Certified Global Sanctions Specialist (CGSS), or Certified AML and Fraud Professional (CAFP) or willingness to obtain, preferred.

SOFTWARE SKILLS REQUIRED

Intermediate: Alphanumeric Data Entry, Contact Management, Database, Presentation/PowerPoint, Spreadsheet, Word Processing/Typing

Basic: 10-Key, Accounting, Human Resources Systems

INITIATIVE AND INGENUITY

SUPERVISION RECEIVED

Under direction where a definite objective is set up and the employee plans and arranges own work, referring only unusual cases to supervisor.

PLANNING

Considerable responsibility with regard to general assignments in planning time, method, manner, and/or sequence of performance of own work; may also occasionally assist in the planning of work assignments performed by others within a limited area of operation.

DECISION MAKING

Performs work operations which permit frequent opportunity for decision-making of minor importance and also frequent opportunity for decision-making of major importance, either of which would affect the work operations of small organizational component and the organization's clientele.

MENTAL DEMAND

Very close mental demand. Operations requiring very close and continuous attention for control of operations which require a high degree of coordination or immediate response. Operations requiring intermittent direct thinking to determine or select the most applicable way of handling situations regarding the organization's administration and operations; also to determine or select material and equipment where highly variable sequences are involved.

ANALYTICAL ABILITY / PROBLEM SOLVING

Directed. Supervisory and/or professional skills using structured practices or policies and directed as to execution and review. Interpolation of learned things in moderately varied situations where reasoning and decision-making are essential.

RESPONSIBILITY FOR WORK OF OTHERS

Carries out supervisory responsibilities in accordance with the organization's policies and applicable laws. Responsibilities may include but not limited to interviewing, hiring and training employees; planning, assigning and directing work; appraising performance, rewarding and disciplining employees; addressing complaints and resolving problems.

Supervises a small group (1-3) of employees in the same or lower classification. Assigns and checks work; assists and instructs as required, but performs same work as those supervised, or closely related work, most of the time. Content of the work supervised is of a non-technical nature and does not vary in complexity to any great degree.

Supervises the following departments: AML Policy and Governance Analysts

RESPONSIBILITY FOR FUNDS, PROPERTY and EQUIPMENT

Occasionally responsible for organization's property where carelessness, error, or misappropriation would result in moderate damage or moderate monetary loss to the organization. The total value for the above would range from $5,000 to $150,000.

ACCURACY

Probable errors would not likely be detected until they reached another department, office or patron, and would then require considerable time and effort to correct the situation. Frequently, possibility of error that would affect the organization's prestige and relationship with the public to a limited extent, but where succeeding operations or supervision would normally preclude the possibility of a serious situation arising as a result of the error or decision.

ACCOUNTABILITY

FREEDOM TO ACT

Directed. Freedom to complete duties as defined by wide-ranging policies and precedents with mid to upper-level managerial oversight.

ANNUAL MONETARY IMPACT

The amount of annual dollars generated based on the job's essential duties / responsibilities. Examples would include direct dollar generation, departmental budget, proper handling of organization funds, expense control, savings from new techniques or reduction in manpower.

Medium. Job creates a monetary impact for the organization from $1mm to $10mm.

IMPACT ON END RESULTS

Modest impact. Job has some impact on the organizations end results, but still from an indirect level. Provides assistance and support services that facilitates decision making by others.

PUBLIC CONTACT

Regular contacts with patrons where the contacts are initiated by the employee. Involves both furnishing and obtaining information and, also, attempting to influence the decisions of those persons contacted. Contacts of considerable importance and of such nature, that failure to exercise proper judgment may result in important tangible or intangible losses to the organization.

EMPLOYEE CONTACT

Contacts with other departments or offices and also frequently with individuals in middle level positions; consulting on problems which necessitate judgment and tact in presentation to obtain cooperation or approval of action to be taken. Also, important contacts with associates as required in advanced supervisory jobs, plus frequent contact with senior level internal officials

USE OF MACHINES, EQUIPMENT AND/OR COMPUTERS

Regular use of highly complex machines and equipment; specialized or advanced software programs.

WORKING CONDITIONS

Periodically exposed to such elements as noise, intermittent standing, walking, pushing, carrying, or lifting; but none are present to the extent of being disagreeable.

ENVIRONMENTAL CONDITIONS

The following work environment characteristics described here are representative of those an employee encounters while performing essential functions of this job. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.

The noise level in the work environment is usually moderate.

PHYSICAL ACTIVITIES

The following physical activities described here are representative of those that must be met by an employee to successfully perform the essential functions of this job. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions and expectations.

Semi-repetitive, low physical. Semi-repetitive type work which requires periods of concentration for varied time cycles as prescribed by the tasks.

While performing the functions of this job, the employee is continuously required to sit, use hands to finger, handle, or feel, talk or hear; occasionally required to stand, walk, reach with hands and arms, stoop, kneel, crouch, or crawl. The employee must occasionally lift and/or move up to 25 pounds. Specific vision abilities required by this job include close vision.

ADDITIONAL INFORMATION

7 years of experience in banking, compliance, risk management, audit, regulatory, or a related field within financial services OR an equivalent combination of education and experience is required.

5 years of experience working within a financial crimes and/or AML governance related function within financial services is required. A combination of this experience, as well as, AML investigations, EDD reviews, OFAC, and other similar experience, is preferred. Knowledge of various BSA/AML monitoring software.

Extensive knowledge of BSA/AML, OFAC, and FinCEN-related laws/regulations. Knowledge of AML/Know Your Customer (KYC) related issues. Strong investigative skills with the ability to work independently. Skill reading, analyzing and interpreting Federal and State Banking Regulations. Proficiency using Microsoft Office software products such as Word, Excel and PowerPoint.

Bachelor's degree in Business Administration, Risk, or a related field or an equivalent combination of education and experience.