The Assistant BSA Officer and Financial Crimes Manager is responsible for overseeing the Bank's BSA/AML/OFAC Compliance Program as well as the day-to-day operations of the Financial Monitoring Unit ('FMU') including the detection, mitigation, and reporting of potentially suspicious activity.
Duties and responsibilities include:
- Assist the BSA Officer in supervising and overseeing the day-to-day compliance with the Bank's BSA/Anti-Money Laundering and OFAC Compliance Program.
- Responsible for managing the FMU including hiring, training and employee development, recognition, performance management, promotions, dismissals, and disciplinary action.
- Develop and maintain an understanding Amerant's lines of business and products, and red flags/ money laundering typologies related to Amerant's product suite.
- Identify, evaluate, monitor and make any recommendation deemed necessary to the BSA/AML Officer in order to assess, reduce, eliminate, or control any current or prospective BSA/AML/OFAC risks arising from violations of, or nonconformance with, laws, rules regulations, prescribed practices, or internal policies and procedures
- Interact with multiple groups within the BSA Department, and act as the subject matter expert ('SME') on investigative techniques, and regulatory requirements. Advise senior management on transaction monitoring coverage and required resources.
- Perform duties in accordance with Amerant's compliance governance documents.
- Develop and approve policies and procedures as needed according to Amerants's compliance governance documents.
- Develop and incorporate updates to the transaction monitoring review process as needed.
- Create and compile monthly and quarterly metrics, stats, and pertinent information for presentation to BSA Officer and appropriate committees as needed.
- Draft content of employee BSA/AML and OFAC training, prepare training decks, present training to employees and track attendance and/or completion.
- Be aware of new rules and regulations that would impact Amerant and update policies, procedures, and processes as appropriate.
- Approve SAR filings as needed and ensure timely review of alerts, investigations. Ensure SAR filings and continuing SAR filings are completed in the timeframes outlined in Amerant's compliance governance documents.
- Oversee investigations related to positive 314(a) matches, National Security Letters (NSL), Grand Jury and criminal subpoenas and ensure SARs are filed as needed. Additionally, determine the timeframe for the respective investigations.
- Ensure quality assurance on SARs filed as a result of 314(a) matches, NSL, Grand Jury, criminal subpoenas and fraud are performed as appropriate.
- Directly perform investigations relating to internal fraud, insider abuse or employee-related matters as applicable.
- Review internal tips and assign investigations as needed.
- Approve extensions to alert reviews, investigations, and requests for information.
- Assist the BSA/AML Officer with ensuring that BSA/AML/OFAC policies and procedures are updated as needed or at least annually, preparing all documentation and reports necessary for BSA Committee meetings, and with all BSA/AML/OFAC related projects as necessary.
- Ensure that the implementation and maintenance of the monitoring program for the bank on Office of Foreign Assets Control (OFAC) and section 311 of the USA PATRIOT Act are carried out as well as the processes and controls to maintain an effective sanctions program and CTR reporting.
- Ensure that all departmental BSA/AML initiatives are current and ongoing and BSA/AML/OFAC related Action Plans are addressed timely, and report to the BSA/AML Officer any deviations.
- Design and oversee the compliance training program for the Board of Directors, Executive Committees, officers and employees.
- Assist the BSA/AML Officer with monitoring employee performance and rating employees for BSA/AML compliance. Recurring failure to adhere to policies and procedures will be duly noted in the respective employee's personnel file and brought to the attention of the BSA Committee.
- Maintain extensive level of expertise in BSA, AML and sanctions regulations, regulatory issuances and examination materials, industry trends and best practices. Analyze the impact of anti-money laundering and OFAC regulations within the business, operational and compliance processes of Amerant. Keep abreast of all pertinent regulatory changes and update testing processes as required.
- Identify, evaluate, and report to the BSA/AML Officer any current or prospective risks from violations of, or nonconformance with laws, rules, regulations, and prescribed practices.
- Complete all required internal training and other optional external and internal trainings, as necessary.
- Maintain a detailed knowledge and operational skill set of applicable Microsoft office suites.
- Learn and maintain a working knowledge of all internal systems, as applicable and necessary to perform duties.
- Comply with all applicable Human Resources policies and procedures.
- Other duties assigned by Supervisor.
Minimum Education and /or Certifications:
Bachelor's Degree in Finance, Business Administration, Economics or related field; ACAMs or CRCM certification preferred.
Minimum Work Experience Requirements:
Minimum ten years in a BSA/ AML Compliance or Internal Control position in the banking industry, preferably in anti-money laundering compliance in an international banking environment. Experience in people management. Bilingual English/Spanish preferred.
Technical and/or Essential Knowledge:
Strong knowledge of applicable BSA/AML and OFAC regulations and compliance controls. Knowledge of banking financial principles, products and process involved in banking activities. Working knowledge of brokerage and trust company activities preferred.