Responsible for managing a team of Compliance Officers in the execution and coordination of an enterprise-wide OFAC and Sanctions compliance program. Also responsible for BSA/AML/OFAC compliance oversight of banking activities engaged in by various business lines as they relate to jurisdictions outside the United States. This includes oversight of foreign correspondent banking due diligence, trade finance operations compliance, foreign exchange transactions, foreign wires, ACH, SWIFT, Pacific Rim Division, as well as business initiatives that may require compliance with foreign anti-money laundering / counter terrorism financing (AML/CTF) and/ or sanctions regulatory requirements.
Develops, implements, and maintains an effective OFAC/sanctions compliance program across all business lines.
Develops, implements, and maintains an effective foreign banking compliance program for appropriate business groups.
Develops, implements, and maintains the Bank’s OFAC policy and related procedures, and oversees business line compliance with same.
Develops and performs the annual OFAC risk assessment.
Identifies risks and major compliance obligations (MCOs) related to OFAC / sanctions compliance and foreign banking compliance; assesses and advises on corresponding controls and control effectiveness.
Maintains the Bank’s foreign correspondent bank matrix.
Develops and delivers enterprise-wide OFAC/sanctions compliance training; oversees and assists with development and delivery of business line specialized OFAC training and/or foreign banking AML/CTF compliance training as required.
Ensures that the Bank’s businesses have implemented appropriate OFAC screening tools in accordance with the Bank’s OFAC policy, and maintains effective oversight of ongoing OFAC screening throughout the Bank.
Develops centralized processes and systems for OFAC screening and compliance monitoring as appropriate.
Assists in the development and/or enhancement of business line OFAC automated screening tools.
Acts as point of contact for all escalations by the business of OFAC/sanctions related decisions (eg. makes decisions on unresolved positive matches generated by screening of sanctions lists; handles business requests for exceptions to procedures; advises on requirement for customers to obtain licenses, etc.)
Serves as the primary point of contact with regulators at OFAC; performs sanctions regulatory reporting to OFAC, including preparing and submitting blocked and rejected transactions reports, making voluntary self-disclosures, responding to OFAC requests for information, etc.
Handles all OFAC related reporting to internal stakeholders and prepares the Banks OFAC Annual Report.
Acts as the Bank’s primary subject matter expert on OFAC, sanctions, and foreign banking related compliance; advises businesses as required, including on sanctions and AML/CTF compliance in foreign jurisdictions as they may relate to the Bank’s business activities.
Collaborates with and assists BSA investigations team on investigations involving potential OFAC violations/ sanctions issues.
Assists BSA compliance partners in developing and maintaining the Bank’s country risk matrix.
Assists in the development of OFAC and sanctions testing protocols.
Continually monitors OFAC website and other sources of regulatory updates and disseminates necessary information to affected businesses.
Required Education Or Equivalent Experience
· Bachelor’s Degree required
· Master’s/Advanced Degree preferred
· Required license(s) or certification(s) ACAMS preferred
Required Experience
· 6 to 8 years of directly related experience; 6 to 10 years of business analysis experience
· 5 years of supervisory or managerial experience
· Alternative: Combination of education and experience (years /description) equivalent of 10 years related experience
Field of Experience
· Minimum 10 years related bank compliance experience at major banking institution or regulatory agency
· Strong subject matter knowledge of correspondent banking compliance requirements, foreign bank AML re-certification requirements, non-US anti-money laundering / counter terrorism financing regulatory requirements, and their practical application in a financial services environment
· Strong knowledge of OFAC Sanctions, Anti-Boycott, and other prominent sanctions programs (eg. EU, UN), Bank Secrecy Act, USA PATRIOT Act, and FFIEC Examinations Manual
· Experience dealing with regulatory authorities at a high level
· Knowledge of payment systems (SWIFT, ACH, etc)
· People management experience and experience working across diverse business groups and teams
· Exceptional communication skills (both written and oral); experience making presentations to senior level audiences
· Strategic thinker and thought leader
· Ability to multi-task and work in a fast-paced environment
· Computer literacy required (Word, Excel, etc)
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