POSITION TITLE: BSA/AML Officer
REPORTS TO: Chief Strategy Officer (CSO)
DATE REVISED: October 2023
The BSA/AML Officer is responsible for the implementation and administration of all aspects of CACU’s BSA/AML/OFAC Compliance Program under the guidance of the Chief Strategy Officer. The BSA/AML Officer should understand CACU’s products, services, members, and geographic locations, and the potential money laundering and terrorist financing risks associated with these. This person is also charged with managing all aspects of the BSA/AML/OFAC compliance program and with managing CACU’s adherence to the BSA and its implementing regulations. The BSA/AML Officer shall be fully acquainted with the provisions of the BSA. It is imperative for the BSA/AML Officer to stay informed on the subject and serve as the subject matter expert on BSA/AML/OFAC related issues. The BSA/AML Officer also guides and directs the BSA Analyst(s) in supporting the BSA/AML/OFAC Program.
ESSENTIAL DUTIES AND RESPONSIBILITIES: (including the following and others as assigned)
- Serve as CACU’s BSA/AML/OFAC compliance officer.
- Administer, maintain, and monitor CACU’s day-to-day compliance with our BSA/AML/OFAC Program and related laws, regulations, policies, programs, initiatives, rules and reporting requirements.
- Ensure that all required regulatory reporting is conducted in a timely, accurate, complete and compliant manner, including but not limited to the timely and properly completed submissions of Suspicious Activity Reports (SARs) to FinCEN as well as FinCEN 314(a) and 314(b) procedures and reporting.
- Establish and maintain appropriate SAR investigation, review, and reporting processes that promote consistent decisions, adequate investigation and research, and detailed documentation.
- Conduct CACU’s BSA/AML/OFAC risk assessment annually with consideration to products, services, members, and geographies that may present BSA/AML/OFAC related risk and collect and report annually.
- Maintain and update BSA/AML/OFAC policies and procedures.
- Identify and analyze transactions on an ongoing basis for suspicious/unusual activity both manually and through CACU’s BSA/AML monitoring software.
- Support BSA/AML Analyst in timely reviews of activity and BSA/AML monitoring alerts.
- Coordinate the gathering and perform review of due diligence information from new and existing member credit unions, updating risk ratings as appropriate.
- Conduct and document periodic reviews for existing members, performing enhanced due diligence as needed on high or elevated risk members.
- Administer CACU’s BSA/AML/OFAC training programs and provide BSA guidance and coaching to employees.
- Assist with regulatory examinations and audits, including gathering requested information and working with CSO to coordinate responses to such reviews as necessary.
- Communicate with compliance staff at member credit unions as necessary to obtain additional information on transactions for their members.
- Maintain familiarity with laws, regulations, industry trends, and current events to ascertain CACU’s compliance with regulations and legislation.
- Communicate with local, state, and federal law enforcement and other related government agencies as needed.
- Write technical and management reports which include reports for the board of directors.
- Perform other duties as assigned.
- Bachelor’s Degree in related field
- Eight to ten years of similar or related experience in compliance in the financial services industry
- Certification such as Certified Anti-Money Laundering Specialist (CAMS)
- Thorough knowledge of key BSA/AML/OFAC regulations.
- Comprehensive understanding of general CACU operations, activities, products, and services.
- Strong interpersonal, communication and organizational skills with the ability to work both independently as well as collaboratively within a team environment.
- Strong decision making, analytical and investigative abilities with attention to detail and accuracy.
- Ability to continuously exercise judgment following broad guidelines, identifying and selecting complex choices of action where standard practices may not exist using analytical reasoning.
- Ability to interact effectively with all levels of staff, management, regulators and examiners while maintaining strict confidentiality.
- The ability to perform multiple tasks and prioritize accordingly.
- Working knowledge of Microsoft Office Suite
DEPARTMENT AND/OR JOB SPECIFIC COMPLIANCE REQUIREMENTS:
- Adhere to Corporate, departmental and governmental policies and regulations, laws and policies.
- Comply with BSA/AML/OFAC rules, regulations, policies and procedures.
- Ensure that staff is in compliance with all regulations.
- Act as the Assessment Process Owner for Enterprise Risk Management.
- Maintain the Risk and Control Self-Assessments for his/her assessment unit.
- Identify and track Key Risk Indicators on a quarterly basis for his/her assessment unit.
- Coordinate risk identification and control enhancement activities with the Risk Manager.
- Monitor and report the progress of control enhancement initiatives.
PHYSICAL DEMANDS AND WORK ENVIRONMENT:
- This position is performed in an office setting.
- The work environment and physical demands of this position are representative of similar jobs in comparable companies.