Position Summary:
The BSA Officer is responsible for managing the day-to-day implementation, administration, and ongoing enhancement of the Bank's Bank Secrecy Act (BSA), Anti-Money Laundering (AML), and Office of Foreign Assets Control (OFAC) compliance programs. This role leads a team of approximately 10 BSA/AML professionals and ensures the Bank maintains an effective, risk-based program that supports safe and sound growth across Wisconsin and Illinois. The BSA Officer serves as a key partner to business lines and second-line functions, provides meaningful reporting to Senior Management and the Board of Directors, and supports examinations, audits, and continuous improvement initiatives.
RESPONSIBILITIES:
Program Administration & Operations
- Manage day-to-day execution of the Bank's BSA/AML and OFAC programs, ensuring alignment with a risk-based approach and applicable regulatory requirements.
- Oversee accurate and timely Currency Transaction Report (CTR) processing, including quality control, escalation, and reconciliation of filing volumes and exceptions.
- Oversee Customer Identification Program (CIP) controls and Beneficial Ownership/Legal Entity onboarding and monitoring activities, including issue tracking, remediation, and trend analysis.
- Administer the customer risk rating methodology and ongoing monitoring processes to ensure risk ratings remain current and reflect the nature, purpose, and risk profile of customer relationships.
- Oversee Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) reviews, including periodic reviews of higher-risk customers and documentation standards.
- Oversee suspicious activity monitoring processes, alert disposition workflows, escalation protocols, and documentation standards to ensure regulatory defensibility.
- Oversee the investigation, decisioning, and filing of Suspicious Activity Reports (SARs), including continuing activity monitoring and SAR quality assurance.
- Oversee sanctions/watchlist screening processes (customer and transactional screening), escalations, disposition documentation, and any required blocking/rejecting and reporting.
- Coordinate and manage information sharing requests and processes (e.g., 314(a) and 314(b)) and support lawful requests from law enforcement and other financial institutions.
Risk Assessments, Governance & Reporting
- Lead and/or support periodic BSA/AML and OFAC risk assessments (including products/services, customers, geographies, delivery channels, and emerging threats) and ensure timely action plans and control enhancements.
- Maintain and update BSA/AML/OFAC policies, procedures, and program documentation, incorporating regulatory changes, examination findings, model/monitoring changes, and operational improvements.
- Develop meaningful management information (MI), key risk indicators (KRIs), and key performance indicators (KPIs) that provide insight into program effectiveness, workload, timeliness, quality, and emerging risks.
- Prepare clear, actionable reporting and presentations for Senior Management and the Board of Directors (or designated committee), including program metrics, significant issues, SAR trends/themes, and remediation progress.
- Partner with Compliance, Risk, Legal, Operations, IT, and business lines to drive consistent implementation of controls and resolve cross-functional issues.
Audit, Exam & Issue Management
- Serve as a primary point of coordination for BSA/AML/OFAC audits, independent testing, and regulatory examinations, including pre-exam planning, document requests, interviews, and onsite/remote support.
- Own and manage corrective action plans for BSA/AML/OFAC findings, matters requiring attention (MRAs), and internal issues, including root cause analysis, remediation design, validation, and sustainable closure.
- Support model/monitoring validations and ongoing tuning/testing activities for AML and sanctions screening systems, in partnership with internal stakeholders and third-party vendors as applicable.
Training, Advisory & Culture of Compliance
- Enhance and maintain a comprehensive BSA/AML/OFAC training program tailored to job roles and risk exposure, including new hire training, annual training, targeted training, and Board/Senior Management updates.
- Serve as a trusted advisor to frontline teams and bank leadership on BSA/AML/OFAC risk, red flags, escalation expectations, and control requirements.
- Promote a culture of compliance, curiosity, and continuous improvement by encouraging sound judgment, healthy challenge, and consistent documentation.
People Leadership & Development
- Lead, coach, and develop a team of approximately 10 BSA/AML professionals, including goal setting, performance management, training plans, and succession planning.
- Set clear expectations for quality, timeliness, documentation, and risk-based decision making across program activities (e.g., CTRs, CDD/EDD, investigations, SARs, and OFAC escalations).
- Support hiring, onboarding, workload planning, and workflow optimization to ensure adequate coverage and scalable operations as the Bank grows.
- Provide hands-on leadership and a willingness to "wear many hats," stepping into operational needs while maintaining program oversight and strategic direction.
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