Financial Crimes Manager & CFT/AML Officer

 The Financial Crimes Manager & CFT/AML Officer leads the Bank’s enterprise financial crimes compliance program, including Countering the Financing of Terrorism and Anti-Money Laundering (CFT/AML), Bank Secrecy Act (BSA), Office of Foreign Assets Control (OFAC), fraud risk coordination, and related regulatory reporting. The position is responsible for establishing and maintaining effective risk-based policies, controls, monitoring, investigations, training, and governance; advising management and the Board of Directors; and ensuring timely corrective action. This position is appointed by the Bank’s Board of Directors and approved annually.

·       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’s risk-based CFT/AML, BSA, OFAC, customer due diligence, suspicious activity monitoring, and related financial crimes policies and procedures; ensure they are understood and executed consistently across the Bank.

       Conduct and document enterprise financial crimes risk assessments, evaluate the design and effectiveness of controls, and present annual assessments, mitigating factors, and significant residual risks to 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 of higher-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 other governmental authorities.

·         Coordinate with the Security Officer and other stakeholders to identify, assess, investigate, and monitor fraud and other financial crimes risks; determine whether suspicious activity reporting is warranted and ensure decisions to file or not file are thoroughly documented.

·         Respond to requests from law enforcement and governmental authorities regarding suspicious activity, financial crimes investigations, and regulatory filings.

·         Supervise, coach, and direct Financial Crimes Analysts, 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-matter expert for CFT/AML, BSA, OFAC, fraud, and related financial crimes matters, advising banking offices, operations, lending, compliance, risk management, and other departments.

·         Maintain a role-based financial crimes training program, including onboarding, periodic employee training, targeted remedial training, and annual CFT/AML, BSA, OFAC, and financial crimes training for the Board of Directors.

·         Provide annual and interim reporting to the Board of Directors and its committees regarding program effectiveness, key risk indicators, significant investigations and filings, emerging threats, staffing, systems, testing results, and corrective actions.

·         Prepare and update the Financial Crimes staffing and resource assessment at least annually, using appropriate risk, volume, complexity, productivity, and service-level metrics.

·         Maintain complete, accurate, and secure case-management and referral records for suspicious activity, fraud, sanctions, and other financial crimes matters. Maintain the Suspicious Activity Internal Referral 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/Compliance Committee and coordinate enterprise reporting and escalation of material financial crimes risks.

·         Chair the SAR Committee and ensure consistent, well-supported decisions, appropriate escalation, confidentiality, and timely follow-through.

Champion the Bank’s financial crimes risk-management efforts by promoting a strong culture of compliance, delivering training, and presenting risk trends and program priorities to employees, management, committees, and the Board.

         Monitor compliance and program effectiveness through quality assurance, sampling, management information, trend analysis, and control testing; escalate deficiencies and oversee timely corrective action.

·         Partner with Internal Audit, Compliance, Enterprise Risk Management, Information Security, Legal, Operations, and business 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’s financial 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, and independent testing; coordinate responses, remediation plans, and supporting documentation.

·         Bachelor’s degree or a minimum of 5 to 7 years of progressively responsible experience in CFT/AML, BSA, OFAC, fraud, financial crimes investigations, or related banking compliance; or an equivalent combination of education and experience.

·         Prefer experience leading a financial crimes compliance function, managing personnel, overseeing investigations and regulatory 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 matters clearly to diverse audiences, including the Board of Directors.

·         Advanced analytical, investigative, decision-making, and problem-solving skills, including the ability to evaluate complex transactions, customer relationships, typologies, control gaps, and competing risk considerations.

·         Working knowledge of CFT/AML, BSA, OFAC, customer identification, customer due diligence, beneficial ownership, sanctions, information-sharing, suspicious activity reporting, fraud, and financial crimes governance requirements.

·         Proficiency with office productivity tools, data analysis, case-management systems, transaction-monitoring systems, sanctions-screening tools, and regulatory filing platforms.

·         Strong organization, judgment, discretion, time management, and attention to detail, with the ability to prioritize sensitive matters 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.

The following certifications are preferred:

• Certified Anti-Money Laundering Specialist (CAMS)

• Certified Regulatory Compliance Manager (CRCM) or other relevant financial crimes, compliance, fraud, or risk-management certification