BSA​/AML Compliance Officer

About Oli Bank

Oli Bank's mission is to make managing finances as easy as possible. Our vision is an evenly distributed, global, digital-first financial system that levels the playing field.

Our values:
Sense of Urgency, Customer Obsession, Pride in Craftsmanship.

• Culture eats strategy — everyone owns it, everyone can be held accountable to it.
• Culture of ownership — keep the bar high, own decisions, correct and learn.
• Long‑term results over short‑term wins — with urgency.
• Build great systems, make the complex simple, use forcing functions.
• Obsess over the details (culture, customers, product, process, data).
• Bias for action, be bold, disagree‑and‑commit, end with the positive — and mistakes have consequences. There is always room for improvement.

Compliance at Oli Bank is not a back office. It is how we earn the right to move money globally. This role owns that.

The role Designated BSA/AML Officer. You own a risk-based BSA/AML/OFAC compliance program that satisfies FinCEN, OFAC, and OCIF expectations for a FinCEN-registered MSB operating with a Puerto Rico IFE — including SAR decisioning authority, FinCEN 314(a) handling, sanctions screening governance, and Board reporting.

• Own and maintain the risk-based BSA/AML compliance program (CIP/KYB/KYC, beneficial ownership, EDD, ongoing monitoring, recordkeeping) across the MSB and bank programs, with clear capacity‑split documentation for each decision.
• Serve as designated BSA Officer with authority for SAR determinations, SAR filing clocks (31 CFR ), continuing‑activity reviews, confidentiality/no‑tipping, and 314(a) searches (14‑day window, no‑hit logs, no disclosure to subjects).
• Report directly to the Board on program health, trends, and deficiencies — trends and metrics, never case‑file detail in minutes.
• Govern sanctions screening: direct OFAC SLS ingestion/reconciliation, ITA CSL / EU / UK sources, OFAC 50 Percent Rule ownership handling, pre‑submission beneficiary screening, fuzzy‑match disposition, and fail‑closed behavior on screening outages.
• Own OFAC block/reject handling (31 CFR 501.603/601.604, 10‑business‑day reporting) — confirmed matches block; auto‑return/retry only after false‑positive disposition.
• Evaluate onboarding, EDD triggers (high‑risk jurisdiction, complex ownership, volume, PEP/sanctions), and transaction activity for compliance risk.
• Proactively audit processes, KYB artifacts, monitoring alerts, and CIS risk‑scoring dispositions; document findings, remediations, and residual risk.
• Own vendor and counter party compliance touchpoints: compliance sign‑off on vendor reviews where BSA/AML screening or monitoring is implicated.

• Build simple, systemic internal controls with forcing functions — not one‑off customizations. No "100% guarantee" language; design for reasonable, risk‑based, auditable compliance.
• Own the training program (staff, engineering/CIS, Board orientation, alternate/interim BSA coverage).
• Manage independent testing / audit remediation, examiner requests (OCIF, IRS BSA exam for MSB), and the residual‑risk register.

• 3+ years BSA/AML compliance experience in a regulated financial institution; direct experience with a Puerto Rico IFE / OCIF examination cycle required.
• Hands‑on SAR lifecycle: investigation, determination memos, filing clocks, continuing activity, confidentiality. Must be able to evidence SAR decisioning authority.
• Working knowledge of BSA recordkeeping, funds‑transfer recordkeeping (§), FinCEN 314(a), OFAC administration, and MSB obligations (31 CFR Part 1022 vs. bank Part 1020/CIP differences).
• Experience with transaction monitoring / risk‑scoring systems, KYB/KYC vendors, and audit of alert dispositions (false‑positive rationale…