The Bank Secrecy Act (“BSA”) Officer is responsible for developing, implementing and administering all aspects of the Bank Secrecy Act Program and for reviewing and monitoring the Bank’s proper adherence with other areas of compliance as specified below. The incumbent uses independent judgment and discretion, industry standards, and regulatory guidance sampling methods to perform various quality-control reviews and monitor Bank-wide compliance with the Bank Secrecy Act, USA Patriot Act, Anti-Money Laundering, Office of Foreign Assets Control (OFAC) and Customer Identification Program. Incumbent is responsible for advising the Director of Compliance, Chief Risk Officer, Senior Management, and Bank personnel of emerging compliance issues, as well as consulting and guiding the Bank in the establishment of controls to mitigate risks. Incumbent also assists all Bank business-unit level personnel in ensuring department activities run smoothly and efficiently by providing leadership, training, and supervision within the department, as related to BSA issues.
To perform this job successfully, an individual must be able to perform each of the following Essential Duties satisfactorily. Reasonable Accommodations may be made to enable qualified individuals with disabilities to perform the Essential Duties of the position:
- Use independent judgment and discretion to develop, implement, and administer all aspects of the Bank Secrecy Act Compliance Program; assist with independent, state and federal regulator auditor inquiries; review and write BSA, AML, OFAC and CIP related policies and procedures; make recommendations to Senior Management when and where appropriate; submit routine reports to the Audit Committee and/or Board of Directors detailing Bank Secrecy Act issues.
- Perform daily review, monitoring and analysis of various reports, logs, and transaction data to identify trends and unusual activity and to monitor large currency activity; use independent judgment and discretion to determine if transactions are suspicious in nature, such as kiting, significant changes in balances, cash structuring in deposits, loans payments and certificate of deposit purchases, wire or ACH transfers, monetary instrument sales, new account openings, etc.
- Complete and file Suspicious Activity Reports (SARs) ensuring they are properly documented with related narrative and supporting documentation.
- Provide maintenance, follow-up and timely response to the Bank’s OFAC system and FinCEN 314(a) and (b) lists and inquiries; appropriately respond to positive hits detected by the Bank’s AML or OFAC software system.
- Use independent judgment and discretion to identify and mitigate potential risk issues against the Bank; assist in providing BSA, AML, OFAC and CIP compliance support; interact with Bank personnel pertaining to such issues.
- Oversee actions of comprehensive self-testing, independent third party and regulatory audits; make necessary preparations for such audits or exams; coordinate responses to external auditors and regulatory examiners; ensure deficiencies identified from such audits and examinations are corrected.
- Review account opening reports for CIP compliance and accuracy; maintain database of missing information for follow up by branch personnel; identify, monitor and track high-risk customers and accounts.
- Review Currency Transaction Reports (CTRs) completed by branch personnel for accuracy and filing; review daily currency reports to ensure CTRs have been completed for all reportable transactions.
- Use independent judgment and discretion to review, approve or decline requests for statutory US Treasury-defined Designation of Exempt Persons and file approved/required documentation for exemptions; perform regulatory-required annual review of exempt persons.
- Use independent judgment and discretion to ensure compliance with all applicable reporting and recordkeeping requirements and timely distribution of related materials and publications to designated personnel.
- Conduct and/or coordinate BSA, AML, OFAC and CIP training presentations and exercises with all Bank personnel.
This job description and the enumerated Essential Duties are intended to provide general guidelines for job expectations and the employee’s ability to perform the position described. This is not intended to be an exhaustive list of all functions, responsibilities, skills and abilities. Additional functions and requirements may be assigned or assumed by the incumbent as necessary to fulfill the requirements of the position.
The incumbent will spend most of time performing this function in a professional, office-type setting. Occasionally, the position may involve driving a personally owned vehicle.
The incumbent, in the course of physically performing this position, spends time writing, keyboarding, speaking, listening, seeing (such as close, color and peripheral vision, depth perception and adjusted focus), sitting, walking, standing, and reaching.
The incumbent for this position may operate any or all of the following: telephone, smart phone, copy and fax machines, adding machine (calculator), computer terminal, laptop computer, personal computer, tablet, printers, or other equipment as directed.
The work environment characteristics described here are representative of those an employee encounters while performing the essential functions of this job. The physical demands described here are representative of those that must be met by an employee to successfully perform the essential functions of this job. Reasonable accommodations may be made to enable qualified individuals with disabilities to perform the essential functions.
The incumbent in this position must be able to read and understand complex state and/or federal regulatory laws, rules and regulations and related Financial Institution Letters (FILs), Statements of Policy, and similar documents, instruments and complex reports; perform detailed analytical assessments of deposit and/or loan account activity, monitor and review employee transaction activity, and solve and advise others on solving complex problems. Incumbent must also display proficiency in analytical reasoning, math, language, giving presentations, and verbal and written communication. Incumbent must also be able to manage deadlines, multiple concurrent tasks, and constant interruptions.
- Advanced knowledge of state and federal banking compliance regulations and related Bank operations policies and procedures.
- Ability to read, analyze, understand, and interpret general business periodicals, professional journals, and technical procedures.
- Excellent organizational and time management skills with the ability to provide leadership and training for other employees using positive techniques to ensure maximum productivity.
- Intermediate skills in computer terminal and personal computer operation; host computer system; word processing, spreadsheet- and specialty software programs; intermediate keyboarding skills to meet production needs of the position.
- Moderate math skills including, but not limited to, the following: ability to calculate interest, commissions, proportions, and percentages; balance accounts; add, subtract, multiply, and divide in all units of measure, using whole numbers, common fractions, and decimals; locate routine mathematical errors; compute rate, ratio and percent; and draft and interpret bar graphs.
- Exceptional verbal, written and interpersonal communication skills with the ability to apply common sense to perform job duties, advise and instruct others, and train personnel; write reports, correspondence, and procedures; and communicate clearly with customers and employees.
- Ability to exercise independent judgment and discretion and deal with complex problems involving multiple facets and variables in non-standardized situations.
- Ability to work with little to no supervision while performing duties.
- The position requires the incumbent to hold a current, non-suspended driver’s license and a personal motorized vehicle with appropriate insurance coverage as governed by Bank policy. The incumbent may be required to travel in their personal motorized vehicle between Bank and customer locations, or to training/conferences in the course of performing assigned duties and responsibilities. Such travel may include travel both during the day and overnight and in and out of state as required
