Compliance Officer, New York

Position Summary The Sanctions Analyst is responsible for the review, analysis, and disposition of sanctions screening alerts generated from cross-border wire transfers, correspondent banking transactions, and other payment activities. The role ensures compliance with U.S. economic sanctions laws and regulations, including those administered by the Office of Foreign Assets Control (OFAC), as well as the Bank's Sanctions Compliance Program, policies, and procedures. The analyst investigates alerts generated by the Bank's sanctions filtering systems, determines whether potential matches represent true sanctions concerns or false positives, and takes appropriate action to either release transactions or elevate matters for further OFAC investigation. The position also supports identification of sanctions evasion and circumvention typologies and collaborates closely with the Sanctions Manager and other compliance stakeholders to mitigate sanctions risk. Key Responsibilities Sanctions Alert Review and Disposition - Review sanctions screening alerts generated from:

• Cross-border wire transfers
• SWIFT payment messages
• Correspondent banking transactions
• Cover payments
• Trade finance-related transactions (where applicable)
• Correspondent banking relationships and it’s account parties
• Analyze payment details, parties involved, geographic risk factors, and transaction narratives to determine whether an alert represents:
• A false positive match; or
• A potential sanctions concern requiring escalation.
• Conduct detailed name matching and sanctions-related research using internal and external sources.
• Clear non-relevant alerts in accordance with the Bank's sanctions policies and documented procedures.
• Ensure all alert dispositions are appropriately documented and supported by sufficient rationale and evidence.

OFAC Investigations - Escalate potential sanctions hits and true matches to the Sanctions Manager or designated investigations team. - Conduct preliminary investigations involving:

• Originators
• Beneficiaries
• Financial institutions
• Vessel information
• Geographic references
• Transaction narratives
• Gather and analyze supporting documentation and intelligence to assist in regulatory decision-making.
• Prepare clear and concise investigation summaries and recommendations.
• Support decision-making regarding transaction rejection, blocking, escalation, or release.

Correspondent Banking Sanctions Monitoring

• Review payment activity flowing through correspondent and intermediary banking relationships.
• Identify unusual payment patterns that may indicate:
• Sanctions evasion
• Use of shell companies
• Third-country routing
• Obfuscation of sanctioned parties
• Payment stripping or message manipulation
• Escalate emerging sanctions risks and concerns to the Sanctions Manager.

Sanctions Circumvention Detection

• Identify indicators of sanctions evasion or circumvention, including:
• Concealed ownership structures
• Nexus with Sanctions countries
• Complex payment routing
• Use of intermediary entities
• Unusual transaction narratives
• Potential vessel or trade-related red flags
• Communicate findings promptly to management.
• Participate in enhanced reviews and investigations involving potential sanctions evasion activity.

Regulatory Compliance - Ensure compliance with:

• OFAC regulations
• U.S. economic sanctions programs
• Bank Secrecy Act (BSA) requirements, as applicable
• Internal sanctions policies and procedures
• Maintain awareness of sanctions developments, regulatory updates, and changes to sanctions lists.
• Assist in implementing updates resulting from regulatory changes or internal policy enhancements.

Qualifications & Experience Education

• Bachelor’s degree required;
• Professional certifications (e.g., CAMS, CGSS) strongly preferred.
• 5-7 years of sanctions compliance, payment screening, Sanctions investigations, or financial crime compliance experience.
• Experience reviewing sanctions screening alerts and investigations in a banking environment.
• Experience with correspondent banking and international payment processing preferred.
• Familiarity with OFAC regulations and sanction compliance requirements.

- Strong understanding of:

• OFAC sanctions regulations
• U.S. sanctions programs
• Correspondent banking
• Cross-border payment processes
• SWIFT messaging formats (MT and ISO 20022)
• Financial crime compliance principles
• 90,000 to 110,000 USD
• Flexibility to cover the nightshift when required

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