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 RESPONSIBILITIES
This 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
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