The purpose of the High Risk Client Unit (HRCU) is to identify, assess risk, and monitor certain high risk clients and set the industry standard in due diligence focused on high risk clientele. Among the other duties of the HRCU is to recommend account closure or take/recommend other appropriate action based on customer activity, regulatory guidance and the Bank’s risk tolerance.
The Investigator is responsible for delivering subject matter expertise for the CDD/EDD unit based on strong process, communication and adherence to the procedures of AML compliance functions. The Investigator is responsible for conducting initial and ongoing Enhanced Due Diligence (EDD) Case Reviews CDD for the purposes of documenting the EDD for clients that pose greater than normal anti-money laundering risk to the Bank.
Provides a comprehensive understanding of the Bank’s clients, stakeholders and commitment to the integrity of the financial system.
Complete enhanced due diligence for clients identified as high risk.
Prepares and thoroughly documents factual and impartial findings in an accurate and timely manner.
Communicates with branch and department managers, as necessary, in researching and investigating cases.
Documents results of EDD Case Reviews on case management system and meets reporting requirements of both internal and external entities. Compiles data, and maintains necessary records and files to assure efficient and consistent reporting of investigations.
Makes recommendations for closing accounts and performs associated follow up to ensure closure of the accounts.
Maintains a good understanding of the BSA regulations and FinCEN guidelines relative to BSA Suspicious Activity Reporting and current money laundering schemes and investigative techniques required to detect such schemes.
Maintains thorough knowledge of the Bank's systems used to conduct research of customer transaction activity.
Required Education or Equivalent Experience
- Bachelor's degree required
- Required license(s) or certification(s) CAMS preferred
Minimum of 3 years with BSA/AML, CDD or EDD, and / or conducting and managing financial investigations and/or research such as in bank operations, security, compliance, and legal areas including criminal and/or civil litigation, researching, comprehensive reporting &documentation, and pattern recognition.
· Alternative: Combination of education and experience that equates to these requirements.
Field of Experience
- Good knowledge of bank operations, policies and procedures, systems and operating rules.
- Good knowledge of Branch or back-office operations; Branch Customer Service Manager or AML experience at another financial institution preferred.
- Good knowledge of BSA regulations pertaining to suspicious AML-related customer activity.
- Good knowledge of Bank's host systems and eVision, as well as the BSA-related suspicious activity detection systems used by the Bank.
- Written and verbal communications skills
- Strong interpersonal skills
- Analytical and multi-tasking skills
- PC Skills - Windows NT, Word, Excel