Principal - AML​/BSA Governance & Advisory; Hybrid, Richmond, VA)

BSA/AML And OFAC Governance Program Manager

While working within and across the teams in the second line of defense enterprise regulatory risk management program, the BSA/AML and OFAC Governance Program Manager is responsible for identifying, assessing, and providing expert advice on regulatory risk, and working with the lines of business and partners to mitigate compliance risk. The successful candidate will be an analytical thinker, self-starting, with strong communication, influencing, relationship building, and problem solving skills.

The BSA/AML and OFAC Governance Program Manager will use these skills to drive actions that sustain business objectives and processes in a well-managed and compliant way.

Position Accountabilities

• Maintain an understanding of BSA/AML and OFAC relevant laws, regulations, guidelines, and advisories and other regulatory bodies pertaining to economic sanctions, AML, and CTF.
• Provide advisory guidance and effective challenge by providing responses to BSA/AML/OFAC related questions.
• Support regulatory applicability mapping to business (or other line of defense) processes.
• Maintain awareness of emerging risks, assess how they may impact the Bank, and develop and implement risk mitigation strategies to address identified risks effectively.
• Works with functional management to ensure risks are properly identified in new products/services and conversions by attending project meetings

Policy and Procedure Management

• Establish and maintain policies, standards and procedures (PSPs), and controls that demonstrate adherence to relevant laws and regulations.
• Maintains the enterprise BSA/AML and OFAC PSPs, supporting business procedural reviews for regulatory applicability and interpretation accuracy.
• Maintains the BSA/AML and OFAC Program's intranet page on AUB's intranet site.
• Conducts independent reviews of lines of business and applicable non-bank affiliates, BSA, AML, and Sanctions Red Flags procedures, and FIU training materials to ensure compliance with laws and regulations.
• Publishes gap analysis memos to document reviews of procedures and tracks successful remediation of issues identified if applicable.

Risk Assessment and Issue Management

• Collaborate in executing the life cycle of the enterprise BSA/AML and OFAC Sanctions risk assessment, including the support of addressing recommendations, recommendations and communication (e.g. status updates, office hours, etc.).
• Monitor the effectiveness of risk mitigation measures and adjust, as necessary.
• Support issue management activities as per enterprise standards, providing effective BSA/AML and OFAC oversight and engagement regulatory SMEs as necessary.
• Manage oversight, status reporting and escalations, as necessary, to ensure remediation activities are fully satisfied.

Governance Oversight

• Collaborate with other departments, including Legal, Risk Management, Systems and Data Governance, Internal Audit, and Business Units, as needed.
• Works with functional management to ensure alignment with strategy/policies and business line objectives
• Serve as the subject matter expert for AML and Sanctions. Collaborates and guides the lines of business and applicable non-bank affiliates on: AML and Sanctions policies and procedures, identifying control gaps and/or remediation needed; products and service advice relative to FIU impact, audits and exams; managing issues; escalating through proper channels, as needed; and recommending corrective actions for non-compliance.
• Facilitate responses to attestations/questionnaires (e.g., Wolfsberg).
• Facilitate vendor/contract management due diligence and reviews including ongoing risk management, performance and related contractual oversight.

Internal and External Audits

• Coordinate and support internal and external independent assessments (exams, audits, etc.) of the BSA/AML and OFAC Sanctions compliance programs.
• Respond to independent assessment findings and observations, supporting the oversight of remediation planning and associated corrective actions as necessary, in a timely fashion.
• Provide status reporting on all findings, observations and related observations stemming from independent assessments.

Regulatory…