Sponsor Bank EFCC Principal

Overview

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Job Summary

The Sponsor Bank EFCC Principal acts as the definitive authority and lead advisor on the enterprise-wide financial crime compliance (EFCC) governance framework. This role dictates the strategic vision and institution-wide control requirements for adherence to the Bank Secrecy Act (BSA), USA PATRIOT Act, and OFAC. Serving as the primary counsel to the BSA Officer and Executive Leadership, the Principal renders authoritative, risk-based decisions on complex compliance matters and new business initiatives, particularly those involving BaaS and Fintech partners.

This leader directs the enterprise BSA/AML Risk Assessment, governs major regulatory programs, and provides credible challenge across business lines to ensure systemic risks are effectively mitigated. As the lead SME, the Principal represents and defends the Bank's compliance program in critical regulatory examinations and high-stakes audits, safeguarding the organization's license to operate.

• Serve as the primary AML subject matter expert for the due diligence, risk assessment, and onboarding of all new Banking as a Service (BaaS) and Fintech partners, ensuring their control frameworks meet the bank's rigorous standards before integration.
  
  - (20%)
• Provide authoritative, risk-based counsel directly to the BSA Officer, executive management, and the Board of Directors on the specific, inherent, and evolving financial crime risks associated with the BaaS business model.
  
  - (15%)
• Author, maintain, and own the enterprise-wide BSA/AML/OFAC policies and standards, with a specific focus on developing and refining the governance framework for third-party BaaS relationships.
  
  - (10%)
• Direct the new product and initiative approval (NPIA) process for all BaaS-related offerings, ensuring AML risks are identified and requisite controls are embedded in the design prior to launch.
  
  - (10%)
• Lead the execution of the enterprise-wide BSA/AML Risk Assessment, paying special attention to the unique risk typology of the BaaS portfolio, and translate findings into actionable policy updates and control enhancements.
  
  - (10%)
• Act as the primary advisor and liaison to regulatory examiners (e.g., OCC, FDIC, Federal Reserve) and internal audit during examinations, managing all BaaS-related compliance inquiries, policy discussions, and formal responses.
  
  - (10%)
• Develop and present executive-level reporting and Key Risk Indicators (KRIs) for management and Board-level committees, clearly articulating the compliance health, risk profile, and control effectiveness of the BaaS partner ecosystem.
  
  - (10%)
• Provide strategic governance and credible challenge for the remediation of all BaaS-related regulatory findings (e.g., MRAs, Consent Orders) or internal audit issues, ensuring corrective actions address the root cause and are sustainably implemented.
  
  - (5%)
• Benchmark all BaaS-related AML policies, procedures, and controls against regulatory guidance (e.g., FFIEC, FinCEN) and industry best practices to ensure the program remains current, effective, and defensible.
  
  - (5%)
• Establish and govern the three lines of defense model as it applies to BaaS partners, defining the clear roles, responsibilities, and oversight expectations for the business line, compliance, and audit functions.
  
  - (5%)

• High School Diploma or GED
• Certified Anti-Money Laundering Specialist (CAMS)
• 12+ years of experience in BSA, AML, Fraud, Compliance, Audit, Quality Assurance, or Quality Control operations

• Bachelor’s Degree in Business, Accounting, Criminal Justice, Analytics, Law, or Finance.
• Certified Regulatory Compliance Manager (CRCM)
• Certified Fraud Examiner (CFE)
• 15+ years of experience in BSA, AML, Fraud, Compliance, Audit, Quality Assurance, or Quality Control operations

• Structured Query Language (SQL)
• Microsoft Excel Data Analysis
• Microsoft Excel Macros
• Pivot Tables
• Customer Due Diligence (CDD)
• OFAC Compliance
• Bank Regulations
• Risk Training
• Financial Crimes Compliance
• Fraud Risk Management

Director and above

0

• Normal office environment. (Remote or Hybrid), 3 to 4 days per month are required in office if within 60 miles of a posted Bread Financial location.

• Ability to travel up to 10% annually

To perform this job successfully, an individual must be able to perform each essential job function satisfactorily and meet the physical, mental and work environment requirements. Reasonable accommodations may be made to enable qualified individuals with disabilities to perform essential job functions, absent undue hardship.

• Communicate/Hearing
• Communicate/Talking
• Move/Traverse
• Reaching
• Standing
• Stationary Position/Seated
• Typing/Writing

This job description is illustrative of the types of duties…