BSA/AML program ownership •Own and maintain the risk-based BSA/AML compliance program (CIP/KYB/KYC, beneficial ownership, EDD, ongoing monitoring, recordkeeping) across the MSB and bank programs, with clear capacity-split documentation for each decision. •Serve as designated BSA Officer with authority for SAR determinations, SAR filing clocks (31 CFR 1020.320), continuing-activity reviews, confidentiality/no-tipping, and 314(a) searches (14-day window, no-hit logs, no disclosure to subjects). •Report directly to the Board on program health, trends, and deficiencies — trends and metrics, never case-file detail in minutes. Sanctions & screening •Govern sanctions screening: direct OFAC SLS ingestion/reconciliation, ITA CSL / EU / UK sources, OFAC 50 Percent Rule ownership handling, pre-submission beneficiary screening, fuzzy-match disposition, and fail-closed behavior on screening outages. •Own OFAC block/reject handling (31 CFR 501.603/601.604, 10-business-day reporting) — confirmed matches block; auto-return/retry only after false-positive disposition. Client lifecycle & transactions •Evaluate onboarding, EDD triggers (high-risk jurisdiction, complex ownership, volume, PEP/sanctions), and transaction activity for compliance risk. •Proactively audit processes, KYB artifacts, monitoring alerts, and CIS risk-scoring dispositions; document findings, remediations, and residual risk. •Own vendor and counterparty compliance touchpoints: compliance sign-off on vendor reviews where BSA/AML screening or monitoring is implicated.
Controls, training, culture •Build simple, systemic internal controls with forcing functions — not one-off customizations. No “100% guarantee” language; design for reasonable, risk-based, auditable compliance. •Own the training program (staff, engineering/CIS, Board orientation, alternate/interim BSA coverage). •Manage independent testing / audit remediation, examiner requests (OCIF, IRS BSA exam for MSB), and the residual-risk register.