Bank Secrecy Act Officer

Employee Name:

Job Title: BANK SECRECY ACT OFFICER

Department: Anti-Money Laundering Division

Reports To: Director of Risk Management

OVERVIEW OF THE JOB: This position is responsible for directing the Anti-Money Laundering (AML) function of the Enterprise. This person is also responsible for all major decisions regarding the Enterprise Bank Secrecy Act/ AML Compliance Program. They will support Enterprise operating units and branch locations by making all major decisions regarding the Enterprise Bank Secrecy Act / AML Compliance Program. They will direct the work of the BSA Specialist(s) and BSA/OFAC Administrator, including formulating procedures for carrying out the activities of the function.

RESPONSIBILITIES:

a) Directs the Enterprise BSA/AML compliance monitoring program, ensuring that there are sufficient internal controls to promote an effective control environment and prioritizing focus toward areas identified as having the highest levels of risk to the company.

b) Directs and provides assistance on periodic BSA/ AML compliance reviews as they are performed by Department personnel as a means of validating the compliance efforts of various operating units within the Enterprise, and reports results from BSA/ AML compliance reviews performed by Department personnel to the Board of Directors.
c) Oversees all functional areas with respect to suspicious activity investigations.

d) Makes final decisions on possible suspicious activity, and collaborates with the Director of Risk Management on all Suspicious Activity Report (SAR) decisions for reporting to the IRS and Board of Directors.
e) Manages lists of accounts and entities identified by the Enterprise as high-risk, and maintains lists for OFAC, Non-Cooperative Countries and Territories, Non-Resident Aliens, the FBI Control List, and any other list required by the government.

f) Manages annual exemption process, including annual review and bi-annual exemption reporting and re­certification.

g) Leads the process for daily monitoring of potential OFAC matches from ChexSystems and makes final determination of OFAC list “hits”.

h) Leads process for periodic scrubs of PCB database against OFAC list as additions are made to the list, including coordination with the branches for documentation reviews and makes final determination of OFAC list “hits”.
i) Directs efforts to complete preparatory work prior to BSA/ AML regulatory examinations of the Enterprise.

j) Directs the preparation of reports and correspondence as needed to the regulatory agencies.

k) Directs the BSA/ AML compliance training process and participates in training as required.

l) Directs the Enterprise BSA/AML Compliance Program in a positive and effective relationship with bank leaders and other risk managers, which performs its responsibilities in the best interests of the company and its shareholders.
m) Maintains the Enterprise BSA/AML Policy, and leads the development of and/or changes to procedures of various operating units to ensure BSA/AML compliance issues have been adequately addressed. Consults with business units as to any deficiencies, and monitor to insure that required changes are made.

n) Acts as an advisor in new product/service development to ensure that BSA/AML compliance risks are identified and addressed.
o) Participates in compliance training and continuing education to maintain proficiency with laws and regulations affecting financial institutions.

p) Performs analytical reviews studying current and long-range BSA performance of the Enterprise, proposing solutions to any problems that arise, and communicating such issues at Senior Management levels throughout the Enterprise.

EDUCATION AND TRAINING

BA Degree in Business, Accounting, related field OR any combination of education, training, and experience that will provide the required knowledge, skills, and abilities

EMPLOYMENT STANDARDS:

Maintain an effective team-oriented working relationship with all department and bank personnel

Must possess the ability to take initiative and demonstrate dedication and conscientiousness toward responsibilities

Maintains a positive attitude and flexibility toward new assignments.

Must be able to respond well and work under pressure

REQUISITE EXPERIENCE, COMPETENCIES AND SKILLS:

Extensive knowledge of Enhanced Due Diligence (EDD) matters, OFAC regulations, USA PATRIOT Act and the Bank Secrecy Act. Ability to define problems and propose solutions. Strong attention to detail and strong organizational/time-management skills. Ability to effectively complete multiple projects simultaneously, managing time and resources to ensure work is completed efficiently and within established timeframes. Ability to work independently and/or in teams under limited supervision. Ability to establish and maintain effective work relationships both internally and externally. Demonstrated skills in analyzing figures to determine logical solutions, including knowledge of statistical sampling methodologies. Understands and incorporates expense control with ‘bottom line’ responsibility for realizing efficiencies. Strong interpersonal skills evidenced in both verbal and written communications as well as excellent listening skills. Business writing skills and experience. Fundamental knowledge of general banking principles, philosophies, and operations. Ability to provide leadership, motivating and persuading others to address compliance risks without having actual authority over them. Experienced PC user with skill in the use of Windows, Word, Excel, Power Point, and/or other computerized tools that may be utilized on a regular basis.

Added responsibilities

These job responsibilities are considered added responsibilities to the core function of the position, which are necessary to the delivery of superior customer satisfaction and operating efficiency in this office.

Performs other duties, if necessary. (Specific responsibilities will be listed by the supervisor)/p>

Minimum of two years experience in compliance-related activities at a similar firm or banking institution. Understands the Project Management Methodology of the Enterprise and utilizes this methodology to coordinate with others in solving moderately difficult compliance issues related to the Bank’s anti-money laundering function. Responsible for making occasional significant decisions within the normal guidelines of the BSA/ AML Compliance Program. Develops and delivers compliance training programs as needed to support the commitments of the BSA Compliance Training Plan. May provide guidance and oversight to any external resources the bank employs to address risk issues.

Extensive knowledge of compliance regulations, with experience in Enhanced Due Diligence (EDD) matters, OFAC regulations, USA Patriot Act and the Bank Secrecy Act. Minimum of three years of financial institution compliance experience and all requisite knowledge and training involved in grade 14, including 60 CRCM-approved compliance training hours every three years. Participates in the comment letter writing process for regulatory proposals. Coordinates with line units throughout the Enterprise to integrate policies and procedures in an effort to ensure compliance with new, or major changes to, federal and state regulatory requirements concerning anti-money laundering. Responsible for making significant decisions regarding the Enterprise Bank Secrecy Act! AML Compliance Program. Supervises others, including establishing standards for performance. Performs analytical reviews studying current and long-range BSA performance of the Enterprise by annually updating the BSA/AML Program and communicating results of compliance with such programs during BSA/ AML Task Force Meetings.

Extensive knowledge of Enhanced Due Diligence (EDD) matters, OFAC regulations, USA Patriot Act and the Bank Secrecy Act. Minimum of five years of financial institution compliance experience, specifically BSA/ AML laws and regulations, and all other requisite knowledge and training involved in grade 15. Demonstrates risk management skills, including prioritizing risk, and demonstrates expertise in managing the examination process. Responsible for major decisions regarding the Enterprise Bank Secrecy Act/ AML Compliance Program. Supervises others; including establishing standards for performance and formulating procedures for carrying out the activities of the Department. Performs analytical reviews studying current and long-range BSA performance of the Enterprise, proposing solutions to any significant regulatory problems that arise, and communicating such issues at Senior Management levels throughout the Enterprise.