Director, AML​/CFT Risk Assessment

About the Role

The Director, AML/CFT Risk Assessment and Program Effectiveness leads the design, execution, documentation, and continuous enhancement of a dynamic, risk‑based AML/CFT risk assessment framework for the bank’s BaaS and embedded finance activities. The role ensures the framework is effective, reasonably designed, and calibrated to the bank’s size, complexity, risk profile, FinCEN AML/CFT priorities, regulatory expectations, and evolving illicit finance risks. The Director serves as a subject‑matter expert and cross‑functional partner, working closely with the first, second, and third lines of defense to identify, assess, document and mitigate financial crimes risk.

• Direct and manage the enterprise‑wide AML/CFT risk assessment program, including periodic and event‑driven refresh cycles, methodology updates, and governance reporting to board and executive committees.
• Oversee and execute the risk assessment process to identify and evaluate the bank’s AML/CFT risks across customers, products, services, geographies, delivery channels, partners, and transaction activity, translating assessment outputs into actionable findings, residual risk ratings, and control gap analyses for senior management and regulatory audiences.
• Incorporate FinCEN AML/CFT priorities, emerging typologies, law enforcement priorities, regulatory feedback, audit findings, monitoring results, SAR/CTR trends, customer due diligence information, and third‑party risk indicators into the assessment methodology.
• Lead the AML/CFT new product, new partner, and business initiative review process as a key second‑line risk reviewer/approver within the bank’s product governance, third‑party risk management, and risk intake framework.
• Conduct comprehensive AML/CFT risk assessments for proposed products, partnerships, distribution channels, and market expansions prior to approval and launch.
• Partner with business development, product management, legal, and compliance teams to identify AML/CFT risk drivers and define required mitigating controls.
• Govern conditions of approval, compensating controls, risk acceptance criteria, launch readiness requirements, post‑launch monitoring expectations, and escalation triggers for higher‑risk or novel initiatives.
• Collaborate with 1
  
  LoD, 2
  
  LoD compliance, technology, operations, and internal audit teams to identify control gaps and ensure appropriate remediation.
• Advise business line leaders on AML/CFT obligations and translate regulatory requirements into operational control standards.
• Represent the AML/CFT risk function in enterprise risk committees, new product committees, and other governance forums.
• Contribute to the development and maintenance of AML/CFT policies, standards, and procedures.
• Serve as primary point of contact for AML/CFT risk assessment–related inquiries, internal/external reviews, and regulatory examinations.
• Prepare and present risk assessment documentation, program narratives, and control evidence for audit and regulatory exams.
• Monitor regulatory developments and industry guidance to keep the framework current.
• Manage, mentor, and develop a team of AML/CFT risk professionals, fostering a culture of analytical rigor, accountability, and continuous improvement.
• Establish team priorities, align resources to workload demands, and drive timely execution of risk assessment deliverables.
• Serve as a thought leader within the AML/CFT function and contribute to the broader financial crimes compliance strategy.

• Advanced degree in Finance, Law, Business Administration, or related field (preferred).
• AML/CFT or financial crimes certification (preferred).
• 8+ years of progressive AML/CFT compliance experience, with at least 4 years in a risk, program management, or leadership role.
• Direct experience in regulated banking environments; experience within BaaS, fintech partnership banking, or OCC‑regulated institutions strongly preferred.
• Demonstrated experience owning and executing enterprise AML/CFT risk assessments and new product review processes.
• Deep knowledge of the Bank Secrecy Act, USA PATRIOT Act, FinCEN regulations, FFIEC AML/CFT Examination Manual, and OCC…