The FIU CTR Administrator will serve as a subject matter expert (SME) and performer of reporting associated with Currency Transaction Reporting (CTR) and CTR Exemptions. This individual is responsible for implementing/deploying a CTR Quality review process to include reviews prior to filing, performing the daily filing queue prior to end of each business day, ownership and maintenance of related procedures along with continuously improving processes that adheres to the Bank Secrecy Act (BSA) and Financial Crimes Enforcement Network (FinCEN) regulatory requirements. The position is responsible for validation between the Bank’s CTR filing to data within the BSA E-Filing system to quickly identify and act upon discrepancies. Responsibilities will also include quick corrective action of all filing error notifications and/or working with FinCEN to determine back filing should the need arise.
Additionally, the FIU CTR Administrator will serve as the designated FIU teammate responsible for identifying and completing reviews pertaining to the Bank’s CTR Exemption process. The individual will be responsible for performing quality reviews on the Bank’s Exemption List and/or population of exempt customers. The position will be instrumental in providing information related to all CTR filings, Exemptions (initial and annual reviews) in preparation for, and during audits and exams.
Position Accountabilities
- Administers the quality reviews of CTRs to validate all regulatory required information is appropriately populated and accurate, ensuring no technical violations of law, as related transactor, conductor, and transactional data requiring filing.
- Oversees the CTR production and CTR quality teams of a third-party performer
- Responsible for partnering with a third-party performer in the Operational oversight of overall CTR process for the Bank, ensuring all reports are submitted accurately and timely via BSA E-Fling on a daily basis.
- Responsible for identifying customers with multiple accounts to ensure accurate cash aggregation.
- Responsible for building partnerships to influence a streamlined and efficient CTR process, all cash sales are transacted appropriately to ensure proper aggregation, and those requiring inclusion of the Bank’s Monetary Instrument Log (MIL) are accurately captured, including ultimate import into the AML system for analyzing and record retention.
- Corresponds with FinCEN on any backfiling requirements, ensuring the AML Risk Manager is kept abreast of findings.
- Escalate exception trends to AML Risk Manager and/or line of business leader(s).
- Provides monthly CTR production (filings, exemptions, annual reviews) statistics to AML Risk Manager and BSA Officer Director.
- Works directly with the FIU Systems-Data Governance team to verify daily feeds are processed correctly (CTR and Monetary Instruments).
- Works with the lines of business to appropriately identify and risk rate cash-intensive customers and those customers with cash-vault and/or courier services, ensuring transactions are correctly processed within the core system for appropriate CTR identification/aggregation and ultimate import into the AML system for analysis.
- Reviews daily exception report and correct transactions where appropriate.
- Performs CTR exemption reviews upon receipt, at identification, and/or annually.
- Oversees the maintenance of the Bank’s CTR Exemption List.
- Decision-maker for CTR filings supporting the first and second lines of defense, to ensure production levels and quality of reviews appropriately identify gaps and result in timely resolution.
- Identifies gaps/weaknesses and works with appropriate leaders to remedy and perform ongoing monitoring to ensure success and sustainability of processes.
- Other duties as assigned.
Organizational Relationship
- Report to –AML Risk Manager
- Oversight of third party performers and processes
Position Qualifications
Education & Experience
- Experience in BSA AML program environments and oversight of quality programs
- Bachelor’s degree in Criminal Justice, Business, or a related field is preferred.
- AML Certification (CAMS, CAFP) or other similar certification is preferred.
- Must have a minimum of 5 years demonstrated experience in BSA AML related role, with at least 3 years of CTR experience.
- Must have 2 years’ experience in an oversight role
Knowledge & Skills
- Experience and knowledge of BSA AML regulatory and program requirements
- Advanced communication skills with ability to interact with senior management, vendors, and other business lines with tact and diplomacy while achieving stated objectives
- Advanced written, oral, data analytics, interpersonal and negotiating skills with ability to prepare and present Quality reports and provide feedback.
- Working knowledge of financial institution operations. Ability to research, analyze and recommend improved processes with a detail and results-oriented mindset
- Ability to read, analyze and interpret government regulations, trade journals, legal documents, and technical documents.
- Advanced PC skills including word processing, spreadsheet, and database applications.
- Considerable understanding of the business lines’ operations, products/services, systems, and associated risks/controls
- Currency Transaction Reporting and Purchase and Sale of Monetary Instruments experience required
- Ability to meet all daily Quality review and filing requirements.
- Takes initiative and has the ability and organizational skills to work and manage time independently in a high-tempo production and deadline-driven environment.
- Experience in performing and managing Quality reviews with a high level of efficiency along with preparing findings report.
- Ability to balance heavy workload of multiple tasks that may involve risk monitoring, metrics, issue tracking, issue research and resolution, procedure evaluation/recommendation and updates, operational efficiencies, establish/monitor controls, willingness to work on daily operational tasks that involve tight deadlines associated with regulatory filing requirements.
Salary offered will be based on several factors including but not limited to education, work experience, certifications, etc. This position is also eligible to participate in either an applicable incentive compensation plan for the position or a discretionary profit sharing bonus program. General information on our comprehensive benefits package can be found by visiting https://www.atlanticunionbank.com/about/careers/benefits (https://www.atlanticunionbank.com/about/careers/benefits).
We are proud to be an Equal Employment Opportunity employer. We maintain a drug-free workplace.
Equal Opportunity Employer
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