Senior Compliance & Underwriting Analyst

Job Description

About Citcon

Citcon is a global payments company enabling cross-border digital wallet acceptance — WeChat Pay, Alipay, UnionPay and other alternative payment methods — for merchants across the United States, Canada, Australia and Hong Kong.

The Role

We are hiring a Senior Compliance & Underwriting Analyst to own merchant underwriting end to end and to strengthen the policy and control environment around it. This is a hands-on individual reporting directly to the Chief Risk & Compliance Officer.

We use AI-assisted tooling across the underwriting workflow. We are looking for someone who uses those tools well and who knows when they are wrong. The ability to challenge a machine generated conclusion and document why is a requirement of this role, not a bonus.

What You Will Do

Merchant Underwriting & Merchant Risk

• Own new merchant underwriting end to end: KYB and entity verification, beneficial ownership and control structure, sanctions and adverse media, financial review, website and acceptable use policy assessment, and processing history analysis.

• Assess merchant risk against prohibited and restricted business policy; assign risk ratings, set conditions and limits, and write the approve, decline or conditional-approval rationale so it stands on its own in a file review.

• Underwrite higher-risk and cross-border merchant profiles, including marketplaces, aggregation models and merchants of record.

• Conduct periodic merchant reviews and risk re-ratings; identify material change in business model, ownership, volume or chargeback profile and escalate accordingly.

• Manage offboarding and termination workstreams, including settlement holds, reserve decisions, notice documentation and the associated evidence file.

• Partner with Sales, Operations and Product on onboarding and merchant questions while maintaining second-line independence in the decision itself.

• Identify patterns across the portfolio that indicate emerging risk, and propose changes to underwriting criteria based on them.

Policy, Internal Controls & Audit Support

• Draft and maintain underwriting policy, prohibited and restricted business policy, acceptable use policy, and the supporting procedures and desk-level work instructions.

• Run the annual policy review cycle: version control, change logs, cross-references, and routing for management and committee approval.

• Document the internal control environment supporting underwriting and AML — control objectives, owners, frequency, and the evidence each control produces — and keep it testable by a third party.

• Identify control gaps and design practical compensating controls; distinguish a control that exists on paper from one that operates.

• Serve as a working-level point of contact for external auditors, third-party independent AML reviewers, state examiners, and bank and sponsor partner due diligence teams: assemble document request responses, prepare sample populations, and walk reviewers through process.

• Track audit, examination and review findings through remediation to documented closure.

BSA/AML & Money Transmitter Licensing Support

• Support transaction monitoring alert review, sanctions and negative news disposition, and enhanced due diligence on higher-risk counterparties.

• Contribute to Suspicious Activity Report drafting and the annual AML risk assessment.

• Support preparation of the NMLS Money Services Businesses Call Report and annual state license renewals,including data reconciliation with Finance.

• Support the state examination process.

What You Need

Required

• 5+ years in merchant underwriting, merchant risk or business-customer due diligence at a payment service provider, payment facilitator, acquirer, money services business or fintech.

• Demonstrated ownership of underwriting decisions, not just file preparation — you have made approve and decline calls and defended them.

• Experience drafting and maintaining policy and procedure documents that survived external review.

• Working understanding of internal controls: what a control is, who owns it, what evidence it produces, and how it fails.

• Direct experience supporting external audits, independent third-party reviews, regulatory examinations or partner due diligence, including managing document requests and tracking findings to closure.

• Working experience using AI or machine-assisted tools in a risk, compliance or underwriting workflow, with the judgment to challenge their output. Be prepared to describe a specific instance where you overrode a system-generated or AI-generated recommendation, and why.

• Practical BSA/AML knowledge: the BSA, USA PATRIOT Act, FinCEN MSB rules and OFAC sanctions requirements as they apply to a money transmitter.

• Familiarity with money transmitter licensing obligations and state money transmission law.

• Clear, examination-grade written analysis.

• Ability to work core Pacific Time business hours.

Preferred

• CAMS certification, or CFCS, CFE or equivalent.

• Cross-border payments experience; familiarity with alternative payment methods or digital wallets.

• Hands-on experience with NMLS filings or MSB Call Report preparation.

• Exposure to Canadian requirements is a plus: FINTRAC registration and reporting, PCMLTFA.

• Experience with sanctions and adverse media platforms such as World-Check, LexisNexis, Dow Jones and other major vendors.

Location, Hours and Travel

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• Fully remote within the United States with occasional travel (less than 10%) to the headquarters.
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