VP - BSA Officer

About the role

The BSA Officer administers and maintains all aspects of the Bank's BSA/AML Compliance Program, including the elevated due diligence and monitoring standards that apply to the Bank's foreign mission banking relationships. The BSA Officer ensures the Program meets a high standard of compliance with BSA/AML laws, regulations, internal policies, and regulatory expectations, and serves as the Bank's designated subject-matter expert on the unique risk profile of diplomatic and foreign government accounts.

The role reports directly to the Bank's Chief Compliance Officer, partners closely with the Bank President to evaluate and make recommendations on relationship risks, and oversees the BSA Analyst. This is a highly visible position with direct exposure to the Board of Directors, executive management, and federal and state regulators. This role requires in-office presence, with a preference for candidates based in Massachusetts or Washington, D.C.

• Program leadership: Coordinate and oversee a strong, Bank-wide BSA/AML/OFAC Compliance Program that meets regulatory requirements and reflects current industry best practices – including the unique due diligence and monitoring program for the Bank's foreign mission banking relationships. Primary program components include but are not limited to:
• Regulatory reporting, including Currency Transaction Reporting, Suspicious Activity Reporting, 314(a) responses, and OFAC correspondence
• Customer Identification and Verification across all business lines and products
• Customer Due Diligence and Enhanced Due Diligence commensurate with customer and product risk, including initial and ongoing due diligence associated with foreign mission relationships
• Suspicious activity monitoring, including monitoring foreign mission accounts for activity inconsistent with a mission's official purpose Bank-wide compliance with BSA recordkeeping and notice requirements
• Systems oversight: Oversee and administer the Bank's automated BSA/AML monitoring and reporting platform, ensuring the Bank remains current on system functionality and that system parameters and thresholds – including those calibrated to foreign mission and other specialized deposit accounts – remain valid and effective.
• High-risk relationships: Oversee and monitor higher-risk customer relationships, including research and analysis to support customer onboarding decisions across all business lines. Serve as the Bank's BSA/AML subject-matter expert for the Specialized Deposit Group's foreign mission banking practice, applying the risk-based framework in FFIEC/FinCEN interagency guidance on accepting accounts from foreign embassies, consulates, and missions, and partnering with the SDG relationship team on account risk-rating and due diligence decisions for embassies, consulates, and other accredited foreign missions.
• Sanctions compliance: Oversee the Bank's OFAC compliance program and act as subject-matter expert and resource for all sanctions screening matters, including diplomatic and foreign government account screening.
• Risk assessment: Update the Bank's BSA/AML and OFAC risk assessments at least annually, incorporating distinct risk factors associated with foreign mission and other specialized deposit accounts, such as country risk, transaction volume and currency handling, and consistency of activity with the account's stated purpose.
• Audit and exam management: Lead the annual program self-assessment, coordinate with the Bank’s internal auditor that reviews the program, and independently manage the annual regulatory BSA examination, including matters touching the foreign mission banking portfolio.
• Governance reporting: Prepare and present regular BSA/AML program reporting for the Board of Directors and executive management, including risk trends specific to the foreign mission banking portfolio, and advise executive management on emerging BSA/AML and sanctions considerations tied to existing relationships and prospective mission clients.
• Training: Oversee and administer the Bank's BSA/AML training program, including specialized training for staff supporting foreign missions and other…