Our client is primarily a correspondent banking service provider. "Compliance" ensures that all activities undertaken by the branch comply with the US Federal and State Banking Regulations, specifically in regards to the Bank Secrecy Act, the USA PATRIOT Act and US Sanctions laws, rules, regulations and regulatory guidance.
The branch's BSA compliance program is premised on the "four pillars" guidance of the Federal Financial Institutions Examinations Council (FFIEC) and the appointment of the BSA Compliance Officer is the first pillar. The branch's program is governed by a set of policies and procedures and the BSA Compliance Officer is responsible for reviewing these policies periodically and recommending appropriate changes and for ensuring that the branch is in compliance with these.
The policies and procedures include, but are not limited to, provisions that govern transaction monitoring, Know Your Customer (KYC), Enhanced Due Diligence (EDD), filing of SARs, quality control and all issues related to US sanctions against countries/entities (SDN), drug trafficking, organized crime, tax evasion, embezzlement and money laundering. The BSA Compliance Officer is responsible for managing members of the compliance staff as well as overseeing and verifying that all staff are adequately trained in their respective assignments, particularly for BSA, and other regulatory issues and maintaining proper records of training. In addition, the BSA Compliance Officer is responsible for overseeing the independent testing and review of the branch's BSA program.
- Developing, implementing and maintaining strong and robust AML/BSA/OFAC policies and procedures for the branch to ensure proper rules and regulations are followed
- Developing and fostering appropriate governance and controls.
- Providing direction, management and policy framework for the BSA compliance program consistent with prevention (CIP/CDD/EDD), detection (transaction monitoring) and reporting (FinCEN, OFAC and regulatory) industry standards and OFAC sanctions monitoring programs of the branch.
- Creating an environment that fosters teamwork and exceptional service and provide leadership to the compliance team and to US Country leadership team.
- Developing a testing program to assess business line efforts to strictly adhere to the branch's policies and business procedures.
- Revising and updating the branch's BSA Compliance policy in line with any changes in US regulations or changes in the banks products or service delivery channels.
- Developing and managing the branch's AML/BSA/OFAC technology and systems.
- Developing effective MIS for all aspects of the branch's BSA program
- Overseeing the branch's OFAC functions including but not limited to dealing with the Office of Foreign Asset Control of the US Treasury Department as and when required, to maintain the Control Function Checklist (CFC) related to OFAC reports for rejected/blocked items and annual reports including checking of internal database to ensure system updates.
- Bachelor's degree or equivalent, with at least 10-15 years of work experience in the money laundering prevention, detection, and reporting compliance field, preferably with a commercial/correspondent bank background
- Experience in all aspects of AML/BSA/OFAC compliance.
- In-depth knowledge of banking and regulatory requirements.
- Exceptional analytical and problem-solving skills.
- Excellent interpersonal and communication skills - both written and verbal; ability to facilitate discussions around complex issues and bring them to resolution.
- Should possess sufficient knowledge of AML systems and technology.
- Demonstrated leadership qualities.
More information - ben.ellison@twentyrecruitment