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us Position Title: Officer Title: Department: Bank Secrecy Act Compliance Officer Vice President Regulatory Compliance Department
SUMMARY: The BSA Compliance Officer will have the responsibility to ensure that the Bank maintains an effective BSA/AML compliance program, consistent with applicable regulatory requirements and “best industry” practices. JOB FUNCTIONS/DUTIES AND RESPONSIBILITIES Specific Monitoring Responsibilities: OFAC Checking: daily
FinCEN Section 314(a) checking: every two weeks (when a new list is published) Conducts “Know Your Customer” due diligence (BSA/AML Questionnaires, etc.) Performs Politically Exposed Person (PEP) checks on Related Parties of the Customer Conducts Section 311 checks, and sends any required Section 311 notices to customers, counterparties, and sub-custodians Participates in completing the Bank’s Customer Profile/Regulatory Compliance Checklist (“CP/RCC”) for each new Customer and updates of CP/RCC for each existing customer Independently verifies that all account opening regulatory requirements are satisfied Reviews daily reports on the variances from established threshold amounts concerning sources of all new customer assets Reviews daily reports on the activities and holdings in Medium High, High and designated Medium Risk BSA countries Checks all banks, counterparties, brokers, SWIFT messages, securities, custody accounts, subaccounts, third party advisers, vendors and employees against OFAC/FinCEN list. Independently verifies the accuracy of BSA Risk Matrices and the CP/RCC Tests newly generated “KYC” reports developed by IT as user, as needed Assist IT with Compliance related system upgrade projects, as needed
Reviews BSA/AML Questionnaires for Foreign Financial Institution Customers and Sub-custodians, as required Reviews and changes existing monitoring thresholds, quarterly Reconciles BSA Compliance Officer’s data with Operations Administration Department, monthly Coordinates with the business front departments in obtaining completed BSA/AML Questionnaires from FFI customers Independently verifies accuracy of documentation per the Bank’s Policy concerning required Information from Third Party Investment Managers/Advisers with Authority to Instruct concerning customer accounts Independently verifies accuracy of documentation per the Bank’s Policy on Customer Identification Program Requirements for Securities Lending Program Participates in periodical director/management compliance meetings. Act as the Secretary of quarterly BSA/AML management meetings. Act as OFAC Responsible Officer Participates in BSA/AML/OFAC Policy/Procedure making and reviews Participates in the preparation for Bank’s Compliance Seminars and trainings
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Works closely with members of the Legal Department, the Internal Auditor and, as required the Head Office to improve the Bank’s existing BSA/AML compliance program. Works closely with all relevant departments of the Bank to ensure compliance by those departments with their regulatory BSA/AML/OFAC responsibilities, including in connection with account opening and monitoring. Stays current with legal and regulatory changes relating to BSA/AML/OFAC requirements.
5-7 years of experience with BSA/AML/OFAC Compliance within Banking, and good knowledge of issues specifically BSA/AML laws and regulations (FinCEN, OFAC, KYC) 2. Good knowledge of banking operations