Bank Secrecy Act; BSA Officer

The Bank Secrecy Act ("BSA") Officer is responsible for developing, implementing and administering all aspects of the Bank Secrecy Act Program and for reviewing and monitoring the Bank’s proper adherence with other areas of compliance as specified below. The incumbent uses independent judgment and discretion, industry standards, and regulatory guidance sampling methods to perform various quality-control reviews and monitor Bank-wide compliance with the Bank Secrecy Act, USA Patriot Act, Anti-Money Laundering, Office of Foreign Assets Control (OFAC) and Customer Identification Program.

Incumbent is responsible for advising the Director of Compliance, Chief Risk Officer, Senior Management, and Bank personnel of emerging compliance issues, as well as consulting and guiding the Bank in the establishment of controls to mitigate risks. Incumbent also assists all Bank business-unit level personnel in ensuring department activities run smoothly and efficiently by providing leadership, training, and supervision within the department, as related to BSA issues.

To perform this job successfully, an individual must be able to perform each of the following Essential Duties satisfactorily. Reasonable Accommodations may be made to enable qualified individuals with disabilities to perform the Essential Duties of the position:

• Use independent judgment and discretion to develop, implement, and administer all aspects of the Bank Secrecy Act Compliance Program; assist with independent, state and federal regulator auditor inquiries; review and write BSA, AML, OFAC and CIP related policies and procedures; make recommendations to Senior Management when and where appropriate; submit routine reports to the Audit Committee and/or Board of Directors detailing Bank Secrecy Act issues.
• Perform daily review, monitoring and analysis of various reports, logs, and transaction data to identify trends and unusual activity and to monitor large currency activity; use independent judgment and discretion to determine if transactions are suspicious in nature, such as kiting, significant changes in balances, cash structuring in deposits, loans payments and certificate of deposit purchases, wire or ACH transfers, monetary instrument sales, new account openings, etc.
• Complete and file Suspicious Activity Reports (SARs) ensuring they are properly documented with related narrative and supporting documentation.
• Provide maintenance, follow-up and timely response to the Bank’s OFAC system and FinCEN 314(a) and (b) lists and inquiries; appropriately respond to positive hits detected by the Bank’s AML or OFAC software system.
• Use independent judgment and discretion to identify and mitigate potential risk issues against the Bank; assist in providing BSA, AML, OFAC and CIP compliance support; interact with Bank personnel pertaining to such issues.
• Oversee actions of comprehensive self-testing, independent third party and regulatory audits; make necessary preparations for such audits or exams; coordinate responses to external auditors and regulatory examiners; ensure deficiencies identified from such audits and examinations are corrected.
• Review account opening reports for CIP compliance and accuracy; maintain database of missing information for follow up by branch personnel; identify, monitor and track high-risk customers and accounts.
• Review Currency Transaction Reports (CTRs) completed by branch personnel for accuracy and filing; review daily currency reports to ensure CTRs have been completed for all reportable transactions.
• Use independent judgment and discretion to review, approve or decline requests for statutory US Treasury-defined Designation of Exempt Persons and file approved/required documentation for exemptions; perform regulatory-required annual review of exempt persons.
• Use independent judgment and discretion to ensure compliance with all applicable reporting and recordkeeping requirements and timely distribution of related materials and publications to designated personnel.
• Conduct and/or coordinate BSA, AML, OFAC and CIP training presentations and exercises with all Bank personnel.

This job description and the…