The BSA Officer is responsible for the implementation, monitoring and actions related to ensuring compliance with all aspects of the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) Program. This position is appointed by the Bank’s Board of Directors and approved annually.
Essential Duties and Responsibilities
- Ensure compliance with all BSA, AML, USA PATRIOT Act and OFAC regulations by all business units throughout the organization. Collaborate between departments to implement corrective actions, ensuring they meet regulatory standards.
- Maintain and update as needed, the BSA/AML and OFAC Programs of the Bank; ensure this Program is understood and executed across the Bank.
- Risk assess the effectiveness of the BSA/AML and OFAC Programs and controls in place. Submit annual risk assessment and mitigating factors to the Audit Committee of the Board of Directors.
- Lead a team responsible for review of BSA-related internal reports to identify transactions and customers which may need to be reported to appropriate government agencies or require account monitoring as higher risk entities.
- Review completed BSA forms for accuracy and ensure forms (CTRs, SARs, DOEPs) are submitted within specified timeframes to FinCEN. Monitor accuracy of forms completed by banking offices to provide training and feedback. Maintain documentation.
- Coordinate with the Security Officer to identify and monitor fraud risks within the organization; determine if a SAR is warranted and completed thoroughly. When applicable, review non-files for proper explanation of decision making not to file a SAR.
- Respond to requests from law enforcement or government entities regarding filed SARs.
- Supervise and direct activities of BSA Analysts and back-up personnel including the following:
- Respond to questions from banking office staff and serve as senior internal consultant to all departments ensuring ancillary areas are in full compliance with BSA/AML/OFAC regulations.
- Maintain an acceptable BSA Training Program which includes, but is not limited to, providing BSA training to new employees, scheduling of Bank Secrecy Act training for existing employees and providing annual BSA/AML and OFAC Training to the Board of Directors.
- Provide annual BSA/AML/CIP/OFAC reporting to the Board of Directors on the status of the BSA Program and interim reports to the Audit Committee of the Board.
- Update the BSA Staffing Assessment annually, including appropriate metrics, to ensure suitable staffing of the BSA Department.
- Maintain the Suspicious Activity Internal Referral spreadsheet (GAFFE) for tracking purposes.
- Serve as co-chair of the quarterly Bank’s BSA/Compliance Committee.
- Serve as Chair of the SAR Committee.
- Actively advocate the Bank’s Risk Management efforts including training employees and making presentations to various groups of the organization.
- Monitor for compliance with BSA by sampling work and reporting to appropriate management areas found not to be in compliance with regulations and Bank internal policies and procedures for corrective action.
- Partner with the General Auditor to identify areas of BSA/AML/OFAC regulatory compliance risk.
- Stay abreast of changes to federal and state banking laws and regulations and bank internal changes and products affecting the Bank’s adherence to BSA and regulatory compliance.
- Coordinate with legal counsel and bank operating departments to ensure adherence to laws and regulations relating to new and/or revised bank products and services.
- Act as lead contact for all BSA regulatory exams.
- Bachelor’s degree or a minimum of 5 to 7 years related BSA Officer experience, or an equivalent combination of education and experience.
- Strong oral and written communication skills, with ability to communicate complex matters to diverse audiences.
- Ability to speak effectively before groups of employees or organization and the Board of Directors.
- Ability to compute basic to moderately complex math calculations.
- Basic problem-solving, research and analytical skills. Ability to interpret a variety of instructions furnished in written, oral, diagram, or schedule form.
- Proficiency in using personal computers and office products (e.g., Word, Excel, Adobe).
- Effective time management skills. High attention to detail.
- Experience with AML software: Verafin and FIS Horizon preferred.
- Strong understanding of financial crimes, AML/Fraud typologies and controls.
Certificates, Licenses, Registrations
The following certifications are preferred:
Certified Anti-Money Laundering Specialist (CAMS)
Certified Regulatory Compliance Manager (CRCM)