Working as a member of the Financial Intelligence Unit (FIU) Risk Assessment (RA) team within Financial Crimes Governance (FCG), the Compliance Officer – BSA/AML and OFAC Risk Assessments is responsible to lead the Risk Assessment team in the preparation and documentation of the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Asset Control (OFAC) Risk Assessments. The BSA/AML Risk Assessment evaluates customers, products, services, delivery channels, and geographies for money laundering, terrorist financing, and other financial crime risks for KeyBank and its lines of businesses (LOBs), while the OFAC Risk Assessment evaluates customers, products, services, delivery channels, and geographies for OFAC risks for KeyBank and its lines of businesses. The candidate is expected to provide upfront data/information requirements for identification and assessment of risks and controls, and work with stakeholders within FCG team to collect and analyze the information to develop an accurate BSA/AML and OFAC risk profile of the Bank. This candidate is expected to take this analysis and write a concise and clear summary of the inherent risks, evaluation of the controls, and assessment of the residual risks related to the BSA/AML and OFAC programs. The candidate must possess strong analytical, reasoning, and writing skills, as well as expected to possess and maintain an understanding of BSA/AML and OFAC programs and related elements.
ESSENTIAL JOB FUNCTIONS
- Responsible to prepare and deliver BSA/AML and OFAC Risk Assessments of KeyBank and its lines of business to the stakeholders.
- Ensure the BSA/AML and OFAC Risk Assessments are in compliance with the FFIEC Exam Manual and meet the expectations of FCG management, internal auditors, and external regulators.
- Responsible to provide upfront data requirements and other information required to measure the risk factors and controls and work with stakeholders within FCG team to acquire and analyze the information.
- Assist in identification and analysis of the risk factors and mitigating controls associated with KeyBank’s products, services, customers, geographic locations, and lines of business.
- Aid in the creation, documentation, and maintenance of policies and procedures for the Risk Assessments, continually evaluating the processes to ensure effectiveness and efficiencies.
- Develop and maintain communications with subject matter experts within FCG and other stakeholders to understand the risks and controls for new products, services, delivery channels, clients, and geographies.
- Assist in efforts to collect information from lines of business and other subjects matter experts using surveys and interviews. Provides support to lines of business to identify and measure the BSA/AML and OFAC risks and provide feedback on the assessment process to drive continuous improvement.
- Develop a level of knowledge of regulatory requirements to identify risk and control factors for inclusion in the assessment process and act as an BSA/AML and OFAC subject matter expert. Research regulations and FFIEC guidance.
- Develop a thorough understanding of KeyBank’s transaction monitoring and investigations, customer identification, customer due diligence, enhanced due diligence, sanctions screening, compliance testing, and BSA/AML and OFAC training policies and programs.
- Monitor and interpret current and future industry trends and BSA/AML regulations and adjusts risk assessment processes accordingly.
- Tracking the status of the BSA/AML and OFAC Risk Assessments throughout their lifecycle to ensure successful and timely completion.
- Excellent verbal, writing, and presentation skills with the ability to interact with stakeholders at all levels within the organization and be able to relay complex technical concepts to non-technical audiences. Preparing reports and presentations based on the results of the BSA/AML and OFAC Risk Assessments.
- Assist with internal and external audits, examinations, regulatory inquiries, and investigation requests for information, as well as, assist in the evaluation of audit and examination findings, implementation of corrective action, and needed responses.
- Assist lines of business to incorporate BSA/AML and OFAC risk and control information in Governance Risk and Compliance (GRC) application.
- Assist in enhancement initiatives and other projects as directed by FIU manager and/or Chief BSA/AML Officer.
- Bachelor’s degree is required, with MBA or JD preferred.
- 5+ years of hands-on BSA/AML and OFAC experience, with consideration given for other Compliance, Risk Management, or Audit roles requiring strong writing and analytical skills.
- Experience with Risk Assessments, and the concepts of inherent risks, controls, and residual risks.
- Knowledge of the BSA/AML and OFAC regulatory, law enforcement, and industry landscape including financial crime laws/regulations, suspicious activity monitoring, customer identification and due diligence, risk assessments, and testing and training.
- Knowledge of banking products and services offered to retail/personal, business, and corporate customers.
- Strong research, analytical, reasoning, and problem solving skills.
- Excellent business writing skills including strong grammar and sentence structure skills with minimum to no management oversight.
- Excellent verbal communication skills, including within the group, lines of businesses, and executive presentations.
- Knowledge and experience in risk management concepts and the ability to effectively manage risk according to established risk tolerances and thresholds.
- Ability to influence and drive change, including proven ability in leading work efforts from conception to delivery with minimal supervision.
- Ability to multi-task and stay self-motivated to effectively manage and complete multiple assignments.
- Goal oriented and able to work independently to achieve results.
- Exceptional relationship building skills, with ability to work and lead in a team environment.
- Advance Microsoft Word, Excel, and PowerPoint skills.
- MBA or JD preferred
- At least 2+ years of team lead experience
- Relevant professional certification (e.g., CAMS, CFE, CRCM)
- Knowledge of risk and control self-assessment (RCSA), including the Governance Risk and Compliance (GRC) application.
- Strong strategic and consultative skills; experience in process improvement, strategic planning, change management, and business integration.
- Comprehensive knowledge of the operational, technical, and functional structure of the KeyBank organization, internal systems, and BSA/AML/OFAC Program.
- Experience with project management principles.
- Experience with financial crime and compliance platforms such as Oracle FCCM/Mantas/Lexis-Nexis Bridger.
KeyCorp's roots trace back 190 years to Albany, New York. Headquartered in Cleveland, Ohio, Key is one of the nation's largest bank-based financial services companies, with assets of approximately $134.5 billion at March 31, 2017. Key provides deposit, lending, cash management, insurance, and investment services to individuals and businesses in 15 states under the name KeyBank National Association through a network of more than 1,200 branches and more than 1,500 ATMs. Key also provides a broad range of sophisticated corporate and investment banking products, such as merger and acquisition advice, public and private debt and equity, syndications, and derivatives to middle market companies in selected industries throughout the United States under the KeyBanc Capital Markets trade name. KeyBank is Member FDIC.
ABOUT THE BUSINESS:
Key Enterprise Risk Management provides leadership on risk management strategies and initiatives for credit, market, compliance and operational risk, as well as portfolio management, quantitative analytics and asset recovery activities. Key's objective is to achieve and sustain strong enterprise risk management practices consistent with industry standards and regulatory expectations in support of business strategies. To reach this goal, risk is identified, measured and managed in a manner that promotes effective decision-making and instills accountability. A strong risk culture is critical to achieving our vision to become the best regional bank in the U.S.
KeyCorp is an Equal Opportunity and Affirmative Action Employer committed to engaging a diverse workforce and sustaining an inclusive culture. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or veteran status.