Deputy BSA Officer - Financial Crimes Compliance

A regulated financial institution is seeking an experienced Deputy BSA Officer to help lead its enterprise-wide financial crimes compliance program. This senior-level position focuses on BSA/AML and sanctions governance, regulatory risk assessments, policy oversight, examination readiness, and program effectiveness.

The successful candidate will partner with senior compliance leadership and teams responsible for customer due diligence, transaction monitoring, investigations, and sanctions to ensure financial crimes controls meet regulatory expectations.

Key Responsibilities

BSA/AML Program Governance

• Serve as the alternate BSA Officer, providing leadership continuity and representing the program in senior management and Board-level discussions.
• Maintain and enhance enterprise BSA/AML and OFAC policies, procedures, and compliance standards.
• Lead annual policy reviews, governance approvals, and documentation updates.
• Ensure consistent implementation of financial crimes controls across business lines and compliance functions.
• Prepare management reporting on program performance, emerging risks, and regulatory matters.

Enterprise Risk Assessment

• Lead the institution's BSA/AML/OFAC risk assessment process, including risk methodology, inherent risk ratings, control effectiveness, and residual risk analysis.
• Evaluate financial crimes risks associated with new products, customer segments, delivery channels, and third-party partnerships.
• Update enterprise risk assessments annually and following significant business or regulatory changes.
• Present and defend risk assessment findings to senior leadership, auditors, and regulators.

Regulatory Compliance & Reporting

• Provide oversight of SAR and CTR processes, regulatory information sharing, and applicable recordkeeping requirements.
• Ensure compliance with FinCEN 314(a) and 314(b) obligations.
• Review investigative and reporting quality in partnership with financial intelligence teams.
• Maintain appropriate documentation, retention practices, and regulatory reporting controls.

Regulatory Examinations & Audit

• Coordinate independent BSA/AML testing, internal audits, and regulatory examinations.
• Manage examination requests, supporting documentation, and cross-functional responses.
• Oversee remediation of regulatory findings, audit observations, and identified control weaknesses.
• Track corrective actions through completion and effectiveness validation.

Training & Program Enhancement

• Direct enterprise financial crimes compliance training, including specialized programs for higher-risk business functions and Board members.
• Collaborate with KYC, transaction monitoring, sanctions, investigations, and quality assurance teams to strengthen program effectiveness.
• Advise business and product teams on financial crimes risks associated with new initiatives.
• Support enhancements to transaction monitoring, case management, and compliance technology platforms.

Qualifications

Required

• 8–12+ years of BSA/AML and OFAC compliance experience within a U.S. bank or regulated financial institution.
• Previous experience as a Deputy BSA Officer, BSA Officer, or senior leader responsible for enterprise BSA/AML program management.
• Extensive knowledge of the Bank Secrecy Act, USA PATRIOT Act, OFAC requirements, and FFIEC examination standards.
• Direct ownership of enterprise BSA/AML/OFAC risk assessments, including methodology development and presentation of findings to regulators or auditors.
• Experience managing BSA policies and procedures through formal governance and Board approval.
• Proven experience coordinating independent testing, federal regulatory examinations, and remediation initiatives.
• Strong understanding of SAR, CTR, FinCEN 314(a)/314(b), and BSA recordkeeping requirements.
• Excellent regulatory communication, analytical, organizational, and stakeholder management skills.

Preferred

• Experience working with money services businesses (MSBs), fintech companies, or virtual asset service providers (VASPs).
• Background within a newly established bank, nationally chartered institution, or OCC-regulated environment.
• Familiarity with OCC supervisory expectations and banking regulations, including 12 CFR 21.21.
• CAMS or comparable financial crimes compliance certification.
• Experience supporting financial crimes technology implementations or optimization initiatives.