Partner Banking Monitoring & Testing Lead

Job Description

POSITION OVERVIEW

We are seeking an experienced Monitoring & Testing Lead to establish and oversee an independent assurance program for fintech and third-party banking relationships. This individual will develop the testing framework, execute risk-based reviews, evaluate control effectiveness, manage findings and remediation, and provide reporting to senior management and governance committees.

The role covers a broad range of partner banking structures and products, including traditional payment activity, digital assets, and stablecoin-related services. This is a hands-on leadership opportunity for someone who has built or led testing programs and understands the regulatory and operational risks associated with sponsor banking and fintech partnerships.

KEY RESPONSIBILITIES

Monitoring & Testing Program

• Build and maintain a comprehensive monitoring and testing framework for partner banking activities, including methodology, testing procedures, workpaper requirements, evidence standards, quality assurance, and reporting.

• Establish and maintain the testing universe, control inventory, and annual risk-based testing plan.

• Determine testing frequency and scope based on partner risk, product exposure, regulatory requirements, and broader enterprise and financial crime risk assessments.

• Perform testing directly while developing the function and expand the team as coverage requirements grow.

Partner & Third-Party Control Testing

• Evaluate controls across different partner banking and account structures, including managed accounts, FBO accounts, omnibus arrangements, and similar models.

• Test the effectiveness of controls performed by third parties where the institution relies on fintech partners for KYC/KYB, transaction monitoring, escalation, or other compliance activities.

• Conduct partner oversight reviews and assessments covering BSA/AML, sanctions, fraud, consumer compliance, and operational controls.

• Evaluate whether partner activities remain consistent with approved structures, risk parameters, licensing requirements, and compliance obligations.

BSA/AML & Sanctions Testing

• Test CIP/KYC/KYB, beneficial ownership, customer risk rating, transaction monitoring, alert and case management, SAR processes, and sanctions screening controls.

• Assess transaction monitoring coverage, scenario effectiveness, tuning practices, investigation quality, and escalation processes.

• Evaluate screening and controls involving higher-risk customers, industries, jurisdictions, counterparties, and transactions.

• Partner with financial crimes and compliance leadership to identify control weaknesses and validate remediation.

Operational, Recordkeeping & Reconciliation Testing

• Test reconciliation and recordkeeping controls associated with partner banking and sub-account structures.

• Assess whether account records and supporting processes meet applicable requirements for deposit account structures and pass-through deposit insurance treatment.

• Review partner licensing and registration requirements relevant to payment and money transmission activities.

• Trace data and transaction flows across partner integrations to identify gaps between documented processes and actual control execution.

Digital Asset & Stablecoin Testing

• Evaluate controls associated with stablecoin and blockchain-based payment activity, including conversion activity, issuance and redemption processes, wallet and counterparty screening, and blockchain analytics.

• Assess controls related to Travel Rule requirements, unidentified or unattributed transactions, and digital asset activity occurring outside traditional banking hours.

• Evaluate whether transaction monitoring and sanctions controls appropriately address digital asset and blockchain-related risks.

Consumer Compliance Testing

• Test partner compliance with applicable consumer protection requirements, including UDAAP/UDAP, Regulation E, Regulation P, and deposit insurance advertising and disclosure requirements.

• Evaluate partner marketing materials, disclosures, complaints, disputes, and other customer-facing processes.

• Expand testing coverage to applicable lending and credit requirements, including TILA, ECOA, and FCRA, as relevant products are introduced.

Issues, Remediation & Validation

• Document testing findings with clear supporting evidence, risk severity, ownership, and root-cause analysis.

• Track corrective actions and remediation commitments through completion.

• Independently validate that remediation is effective and supported by sufficient evidence before issues are closed.

• Monitor completion of required partner reviews, conditional approvals, and other risk or compliance commitments.

Technology & Data-Driven Testing

• Use data analytics, automation, and AI-enabled tools to improve testing efficiency and expand coverage beyond traditional sampling where appropriate.

• Apply data mapping and full-population analysis to identify control weaknesses, anomalies, and potential compliance issues.

• Evaluate technology-supported compliance and due diligence processes to determine whether outputs are accurate, complete, and appropriately controlled.

Leadership & Regulatory Support

• Recruit, develop, and manage monitoring and testing professionals as the function grows.

• Establish consistent testing and documentation standards and provide quality oversight across the team.

• Present testing results, significant control deficiencies, trends, and remediation status to senior management and governance committees.

• Support regulatory examinations and internal audits by preparing testing documentation, evidence, responses, and remediation updates.

• Monitor supervisory guidance and enforcement developments affecting fintech partnerships, third-party banking, and digital assets and incorporate relevant changes into testing coverage.

QUALIFICATIONS

• 8+ years of experience in compliance monitoring and testing, internal audit, risk management, or compliance within banking or financial services.

• Direct experience testing fintech partner, sponsor bank, BaaS, or comparable third-party banking programs.

• Demonstrated experience building or leading a risk-based monitoring and testing program, including ownership of the testing universe, annual plan, methodology, issue management, and senior-level reporting.

• Experience testing or auditing partner banking structures such as managed accounts, FBO accounts, omnibus arrangements, or similar models.

• Experience evaluating reliance on third-party KYC/AML controls as well as related recordkeeping and reconciliation processes.

• Experience conducting fintech partner oversight reviews covering BSA/AML, sanctions, fraud, consumer compliance, and related controls.

• People management experience, including developing and overseeing testing, audit, compliance, or risk professionals.

• Working knowledge of consumer protection requirements applicable to fintech partnerships, including UDAAP/UDAP, Regulation E, Regulation P, and applicable deposit insurance advertising and disclosure requirements.

• Familiarity with regulatory expectations governing third-party relationships, sponsor banking, and fintech partnerships.

• Experience presenting significant findings to senior management or governance committees and supporting federal banking examinations.

• Experience managing findings, overseeing remediation, and independently validating corrective actions through closure.

PREFERRED QUALIFICATIONS

• Experience testing digital asset or stablecoin controls, including blockchain analytics, wallet screening, counterparty screening, or Travel Rule requirements.

• Familiarity with money transmission, MSB, digital asset, or similar licensing and registration requirements.

• Experience addressing significant regulatory findings, supervisory matters, or formal remediation programs through closure.

• Experience within a federally regulated bank or active sponsor banking environment.

• Familiarity with GRC, audit management, data analytics, AI-enabled compliance, or similar technology platforms.

• CAMS, CRCM, CIA, CPA, or another relevant professional certification.