OVERVIEW:
The VP, BSA & Fraud Officer develops, implements, administers, and maintains the Bank’s Bank Secrecy Act (BSA), Anti-Money Laundering (AML), Office of Foreign Assets Control (OFAC), and Fraud Risk programs in compliance with applicable laws and regulations. This role provides strategic oversight of financial crimes prevention, detection, investigations, and regulatory compliance efforts to protect the organization from financial, operational, and regulatory risk, while helping mitigate potential fraud losses to the Bank and its customers. The VP leads the development, implementation, and ongoing administration of policies, procedures, monitoring systems, investigations, and reporting processes related to BSA/AML and fraud.
PRIMARY ACCOUNTABILITIES / RESPONSIBILITIES:
Performs all functions necessary, within scope of authority and expertise, to provide the highest level of compliance with the provisions identified within the Bank Secrecy Act.
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Reviews and continually maintains the Bank’s BSA/AML/OFAC policy, procedures, and administration of the program. Creates and provides BSA/AML/OFAC training to Bank Personnel and Board Members at least annually.
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Maintains oversight of BSA/AML/OFAC compliance for all Bank affiliates. Assists delegates of affiliate companies in the implementation and administration of BSA/AML/OFAC programs.
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Facilitates State and Federal examinations as well as Internal and External audits of the BSA function and coordinates the response to requests for information as required. Responds to examination and audit findings and ensures corrective action of any deficiencies noted in a timely manner.
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Performs a BSA/OFAC/AML Risk Assessment, at least annually, in accordance with BSA/AML/OFAC laws and regulations.
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Ensures timely and accurate submission of regulatory reporting, including the Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs).
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Addresses regulatory changes that impact the Bank’s business lines and collaborates with internal and external resources to ensure continued regulatory compliance when implementing new products, services, and customers to ensure BSA/AML/OFAC risks are identified and monitored.
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Serves as the Bank’s liaison for 314a compliance.
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Provides recurring reporting to Executive Management and subcommittees of the Board of Directors on BSA related activities, operational metrics and initiatives as applicable.
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Serves as the administrator for the Bank’s automated BSA/AML/OFAC solution. Maintains user access to the solution in accordance with Bank Policy.
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Maintains proficient knowledge of the rules and regulations, including but not limited to, the Bank Secrecy Act (BSA), USA Patriot Act, OFAC, Regulation GG, Elder Financial Exploitation, and Corporate Account Takeover.
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Assists in the development, maintenance, communication and internal training on the Bank’s Fraud Management program including the related policies and applicable standards.
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Supports time-sensitive investigations of potentially fraudulent activity generated through transaction monitoring alerts and/or internal referrals. Escalates applicable activity to the necessary internal teams and management as needed.
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Serves as the liaison to law enforcement agencies, including but not limited to Police, FBI, and/or Secret Service, attending applicable court proceedings, and any other tasks relating to fraud.
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Assists in the evaluation of operational risks that could expose the Bank to fraud and makes recommendations for continuous improvements to the Bank’s internal controls, processes or procedures to further mitigate fraud risk.
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Oversees and coordinates internal actions and escalation in response to Vulnerable Customer Financial Exploitation as defined by Bank policy and procedure; serves as the primary contact to the Bank’s internal Financial Exploitation Team and assists with reporting suspected and confirmed cases of exploitation to their applicable agencies as appropriate.
OTHER ACCOUNTABILITIES / RESPONSIBILITIES:
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Oversight of Debit/ATM Card Dispute processing in accordance with Regulation E requirements, timeframes, and internal policies and procedures.
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Performs related and additional duties that may be required by Management.
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Provides necessary resources to direct reports to foster ongoing education and development.
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Assesses the progress and development of direct reports annually through execution of performance reviews.
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Recruiting, training, and developing new employees as needed.
POSITION REQUIREMENTS:
Required Knowledge, Skills, and/or Abilities
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Bachelor's degree in relevant fields (finance, accounting, criminal justice) or its equivalent and at least five years of banking experience.
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Minimum of 5 years of supervisory experience, with demonstrated ability to lead teams, manage performance, delegate responsibilities, and ensure operational goals are met.
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Certified Anti-Money Laundering Specialist (CAMS) Certification sponsored by the Association of Certified Anti-Money Laundering Specialists (ACAMS).
Preferred experience/knowledge:
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A minimum of five to ten years of direct fraud experience, preferably within the banking, financial services, or insurance industries.
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Strong knowledge of internal control concepts relative to banking organizations.
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Proficiency in third party vendor systems (e.g. COCC Insight, Centrix, and Verafin).
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A working knowledge of relevant regulatory requirements and compliance topics.
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Excellent communications, analytical, managerial, organizational, problem solving and decision-making skills.
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Strong written and verbal communication skills.
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Strong interpersonal skills; must be able to interface professionally and collaboratively with all levels of associates.
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Strong problem-solving abilities with both analytical and independent judgement of large sets of data.
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Ability to work in a dynamic environment, handle multiple time sensitive priorities and manage workload based on evolving business needs and regulatory expectations.
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Ability to work proactively and identify solutions to business problems with consideration for known constraints.
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Certified Fraud Examiner (CFE) Certification designation from the Association of Fraud Examiners (CPE) or equivalent industry certification.
SUPERVISORY SCOPE:
The Vice President, BSA & Fraud Officer has oversight responsibility of the following roles that participate in the execution of the BSA and Fraud programs: BSA/AML Analyst, High Risk Portfolio Analyst, CDD/EDD Analyst, Fraud Analyst(s) and the Debit-ATM Card Dispute Specialist(s).
INDEPENDENT ACTION:
Establishes divisional goals and policies within broad scope of Bank-wide objectives. Reviews major or precedent setting decisions with executive officers. Performs work independently within scope of established guidelines and practices. Consults with 1st Senior Vice President, Chief Risk Officer when clarification or exception to Bank policy may be required.
QUALIFICATIONS:
To perform this job successfully, an individual must be able to perform each essential duty satisfactorily. The requirements listed above are representative of the knowledge, skill, and/or ability required. Any physical demands or work conditions described here are representative of those that must be met by an employee to successfully perform the essential functions of this job. Reasonable accommodation may be made to enable individuals with disabilities to perform the essential functions.
