Chief BSA/AML & Sanctions

Job Description

We are seeking an experienced financial crimes executive to lead the organization’s BSA/AML and sanctions function. This senior leadership position will serve as the institution’s formally appointed BSA and OFAC/Sanctions Officer, with responsibility for the design, execution, governance, and continued effectiveness of the financial crimes compliance framework.

The role requires a hands-on leader who can operate effectively with executive management, the Board, regulators, auditors, business leaders, technology teams, and third-party partners. The successful candidate will bring deep banking experience, strong regulatory credibility, and demonstrated success overseeing complex financial crimes programs and remediating significant compliance issues.

This position focuses specifically on BSA/AML, sanctions, customer due diligence, and related financial crimes requirements. Broader consumer and regulatory compliance responsibilities sit outside this role.

Key Responsibilities

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• Serve as the institution’s designated BSA Officer and OFAC/Sanctions Officer, with appropriate authority, independence, and direct access to executive leadership and the Board.
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• Set the strategic direction for the BSA/AML and sanctions program and ensure it remains aligned with the institution’s risk profile, growth strategy, products, customers, geographies, transaction activity, and third-party relationships.
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• Maintain a comprehensive, risk-based financial crimes framework consistent with applicable BSA, USA PATRIOT Act, FinCEN, OFAC, OCC, and related regulatory requirements and guidance.
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• Act as the senior financial crimes contact for regulatory examinations, supervisory discussions, information requests, independent testing, and other regulatory matters.
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• Lead the remediation of regulatory findings, enforcement-related requirements, audit observations, and material control weaknesses, with an emphasis on sustainable corrective action and effective governance.
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• Direct the enterprise BSA/AML risk assessment process and ensure management information provides meaningful visibility into financial crimes exposure and program effectiveness.
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• Oversee CIP, CDD, EDD, beneficial ownership, customer risk rating, high-risk customer oversight, and correspondent banking controls.
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• Provide senior oversight of transaction monitoring, investigations, escalation processes, SAR decisions and filings, and the management of alert and investigative backlogs.
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• Own the sanctions compliance framework, including risk assessments, customer and transaction screening, sanctions-list updates, alert handling, screening methodology, matching logic, and system optimization.
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• Ensure appropriate handling of blocked and rejected transactions, required regulatory reporting, blocked-property records, licensing matters, and potential voluntary disclosures.
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• Assess sanctions exposure associated with international payments, cross-border activity, correspondent relationships, fintech programs, and other higher-risk business arrangements.
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• Oversee required financial intelligence and information-sharing activities, including Section 314(a) and 314(b) processes.
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• Maintain oversight of CTR requirements and applicable BSA recordkeeping, including exemptions, funds-transfer requirements, Travel Rule obligations, monetary instrument records, and foreign correspondent account requirements.
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• Provide governance over financial crimes technology, including transaction-monitoring scenarios, sanctions filters, thresholds, models, data feeds, tuning, validation, case-management platforms, and system performance.
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• Establish effective quality control, quality assurance, testing, issue-management, and control-assurance practices throughout the financial crimes program.
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• Coordinate management’s participation in independent BSA/AML and sanctions testing while maintaining appropriate separation from internal audit and independent reviewers.
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• Maintain an effective process for identifying and implementing changes arising from new regulations, regulatory guidance, advisories, sanctions actions, and evolving financial crimes risks.
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• Provide clear and timely reporting to executive management and the Board regarding program effectiveness, emerging risks, significant issues, remediation status, staffing, technology, and resource requirements.
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• Partner with business, risk, legal, technology, data, audit, and third-party oversight teams to incorporate financial crimes considerations into new products, partnerships, and strategic initiatives.
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• Evaluate the adequacy of staffing, systems, expertise, data, and other program resources and escalate material gaps when necessary.
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• Oversee role-appropriate BSA/AML and sanctions training for employees, management, and the Board.
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• Recruit, develop, and lead a high-performing financial crimes compliance team with clear accountability, strong succession planning, and a culture of transparency and appropriate challenge.
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Candidate Profile

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• 10+ years of progressive BSA/AML and sanctions experience, including at least 5 years in senior leadership within a regulated financial institution.
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• Significant experience leading or providing senior oversight of a bank BSA/AML program, including transaction monitoring, investigations, SARs, CDD/EDD, sanctions, risk assessments, and regulatory reporting.
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• Strong working knowledge of the Bank Secrecy Act, USA PATRIOT Act, FinCEN requirements and guidance, OFAC sanctions requirements, and FFIEC BSA/AML examination expectations.
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• Demonstrated experience working directly with federal and/or state banking regulators.
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• Proven ability to manage significant remediation efforts involving regulatory findings, formal supervisory matters, audit issues, or material control deficiencies.
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• Experience with one or more complex financial services areas such as payment processing, fintech partnerships, Banking-as-a-Service, correspondent banking, international payments, or cross-border activity is strongly preferred.
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• Experience overseeing financial crimes systems and technology, including transaction-monitoring and sanctions-screening platforms, model or scenario tuning, data integrity, and system validation.
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• Strong executive communication skills with the ability to present complex financial crimes matters effectively to regulators, senior management, and Boards.
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• Demonstrated ability to provide independent challenge while maintaining productive relationships with business and control functions.
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• CAMS, CAMS-Audit, CGSS, CFCS, CFE, or another relevant financial crimes certification is strongly preferred.
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• Bachelor’s degree preferred; substantial relevant industry experience and professional credentials may be considered in place of a degree.
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