Summary of Duties:
Monitor various Bank processes and review documents to ensure that the Bank is compliant with regulations, rules, guidance and bulletins related to the Bank Secrecy Act (BSA), Anti-Money Laundering (AML), Office of Foreign Assets Control (OFAC) and Financial Crimes Enforcement Network (FinCEN). Review and file CTRs; ensure that BSA requirements are met in the account opening process; back up the security officer and assist in monitoring AML Manager and Fraud Manager alerts, dismissing or escalating alerts as appropriate.
General BSA/AML/OFAC/FinCEN/Compliance Responsibilities
- Help oversee the Bank’s BSA/AML/OFAC/FinCEN procedures and processes by assisting departments with established policies, procedures and processes.
- Maintain current knowledge of federal and state laws, rules, regulations and guidance by reviewing relevant updates to laws, rules, regulations, agency guidance and bulletins. Ensure that Bank policies, procedures and processes are conducted as per current laws, rules, regulations, guidance and bulletins.
- Assume additional responsibilities as required.
- Review and ensure that Currency Transaction Reports (CTRs) are completed and accurate; log CTR information on our internal spreadsheet, file CTRs in a timely manner (within regulatory deadlines).
- Conduct daily review of AML Manager and Fraud Manager alerts for possible suspicious activity. Dismiss or escalate alerts, as appropriate to the circumstances related to each alert, on a timely basis.
- Set up new hires and delete departing employees in the FIS online compliance training program.
- Set up new hires and delete departing employees in the Bank security badging system.
- Review beneficial ownership forms for proper completion and scan into the Bank’s electronic storage system.
- Assist in Bank’s security system issues and assist the Bank’s BSA/Security Officer in security matters as they arise.
- Undertake research as necessary with respect to potentially fraudulent account activity.
- Perform CIP reviews on a sampling of new accounts.
- Perform OFAC reviews on a sampling of new accounts.
- Perform a review of three months of account activity on selected new accounts to determine whether the information provided at account opening was accurate.
- Conduct monthly Regulation D reviews and prepare customer notification.
- Assign monthly FIS compliance training courses to employees.
- Prepare a past due online FIS compliance training report.
- Undertake the annual CTR exemption review by reviewing exempt customers’ account activities and obtaining documentation as necessary. Update the CTR exemption list.
Garnishments, Levies and Subpoenas
- Assist in processing subpoenas received by the Bank; ensure that requested documents are retrieved, confidential information is redacted; and responses to subpoena requests are sent in a timely manner.
- Act as backup for processing garnishments and levies received by the Bank. This includes learning more about state and federal laws related to garnishments and levies, preparing documentation in response to received garnishments and levies; and retaining records.
- Assist in maintaining our internal log for garnishments, levies and subpoenas.
Community Reinvestment Act
- Review CRA data for accuracy.
- Undertake CRA-qualified activities as needed.