Senior Compliance Officer – Enterprise FinCEN Programs Governance SME

Location:

4910 Tiedeman Road, Brooklyn Ohio

The Senior Compliance Officer serves as Financial Crimes Risk Management’s (FCRM) enterprise subject matter expert (SME) and senior second-line compliance authority for technical compliance with and meeting the spirit of FinCEN Programs such as Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs, including Purchase and Sale of Certain Monetary Instruments Recordkeeping aka Monetary Instrument Log [MIL]), Reports of Foreign Bank and Financial Accounts (FBARs), “Special Measures” Pursuant to Section 311 of the USA PATRIOT Act (Special Measures), and “Information Sharing” Pursuant to Section 314(a) and (b) of the USA PATRIOT Act (Information Sharing).

This role provides enterprise-wide governance, oversight, credible challenge, and strategic guidance to help ensure related processes, procedures, standards, controls, systems, data, and supporting documentation are appropriately designed, implemented, maintained, and operating effectively. The Senior Compliance Officer partners across the first, second, and third lines of defense to identify regulatory risk, assess related control coverage and design, resolve complex matters, drive sustainable remediation, and promote consistent execution across all applicable legal entities, businesses, products, channels, and customer segments.

Serve as the enterprise subject matter expert for and to ensure technical compliance with and meeting the spirit of FinCEN Programs including SARs, CTRs / MIL, FBARs, Special Measures, Information Sharing, and related regulatory requirements and industry practices. Execute risk oversight activities in accordance with the FCRM governance framework, related standards, and requirements. Know and provide compliance oversight of technology evolution / transformation, data governance, data lineage / flows, data quality, data dependencies, data access, data platforms, record retention, system functionality, automated decisioning, rules, models, and other technology changes affecting SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing.

Learn and identify the entire cradle‑to‑grave processes at Key Bank for SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing, including all technology inputs and/or manual processes which could affect outputs, to ensure full compliance with FinCEN Programs. Provide second‑line oversight and credible challenge of all enterprise‑wide processes, procedures, controls, systems, tools, data, and operational practices and facets supporting FinCEN Programs including SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing.

Interpret applicable laws, rules, regulatory guidance, examination expectations, and enforcement themes; assess enterprise impact; and translate requirements into clear policies, standards, control expectations, and implementation guidance. Own and provide authoritative review and approval of enterprise policies and standards for FinCEN Programs including SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing, and oversee the governance of supporting first‑line procedures and job aids.

Evaluate whether controls are appropriately designed to mitigate inherent and residual risks and whether control execution is effective, consistent, evidenced, and sustainable across the enterprise. Identify gaps, emerging risks, inconsistent practices, control weaknesses, and potential regulatory exposure; communicate the risk clearly; and require timely corrective action or formal risk acceptance, as appropriate. Support enterprise risk assessments, including BSA/AML risk assessments, regulatory compliance risk assessments, risk and…