TD8- BSA OFFICER
Houston, TX 77083
#TM – TD8
Location: HOUSTON, TX
The BSA Officer is responsible for carrying out the direction of the VP, General Counsel and ensuring that employees adhere to the Credit Union BSA-AML-OFAC policies, procedures, and processes. Regularly apprise the VP, General Counsel of ongoing compliance. The BSA Officer is responsible for developing, implementing, testing, and administering TDECU’ s BSA-AML-OFAC Compliance Program to ensure compliance with all applicable state and federal laws and regulations including adherence to the BSA and its implementing regulations.
Provide oversight and establish the framework for enterprise wide BSA/AML/OFAC compliance activities. Lead enterprise-wide compliance efforts; creating industry best practices through analysis, sound risk management practices and forward-thinking; and designing and implementing internal controls, policies, and procedures to ensure compliance with applicable local, state, and federal laws and regulations and third-party guidelines. Lead and oversee the activities of the BSA Department and the related responsibilities for implementing the Bank Secrecy Act (BSA)/Anti-Money Laundering Compliance Program and objectives to accommodate current and future organizational needs and ensure compliance with the Interagency Guidelines, industry sound practices, and examination procedures.
Partner with other areas of compliance as well as all business units throughout TDECU to develop and continuously enhance second line of defense compliance risk identification and assessment processes. Maintain vast knowledge about the inventory of compliance risk controls and overall compliance risk levels throughout the company.
Periodically submits status updates to the Board of Directors and annually report to the Enterprise Risk Committee of the Board of Directors detailing the effectiveness of the Credit Union’ s BSA and OFAC Programs.
Essential Duties and Responsibilities:
- Develop and coordinate our efforts to comply with all applicable local, state, and federal laws and regulations and third-party guidelines, including directing the development, implementation, testing and administration of the BSA-AML-OFAC Compliance Program.
- Monitor, review and evaluate new and changing federal and state regulatory compliance requirements in order to design, develop and implement policies, procedures, processes and controls to ensure compliance. Provide technical reviews and testing to ensure they have been effectively implemented. Prepare comments and concerns in correspondence to regulatory agencies regarding pending or proposed regulation. Serve as a resource by providing compliance related research and subject matter expertise.
- Develop and manage our Customer Identification Program, monitoring of high-risk relationships, Office of Foreign Assets Control (OFAC) compliance, and reporting required documentation (such as CTRs, SARs, 314(a)).
- Ensure there is periodic reporting to the Board or a Committee thereof regarding the status of the Program and its ongoing compliance efforts. This report is to provide an overall assessment of our compliance and the directives of the BSA-AML-OFAC policy.
- Perform various quality control reviews and monitoring in the area of Bank Secrecy Act, USA Patriot Act, OFAC and Customer Identification Program using industry standard and regulatory guidance sampling methods to ensure the Credit Union’ s compliance efforts are maintained on a daily basis.
- Review government notifications for updates to high-risk countries, sanctions, and civil money penalties to determine filter settings in the automated AML and OFAC systems.
- Periodically reassess current AML and OFAC filtering systems to ensure accurate filters have been established and mitigate risk of noncompliance.
- Coordinate with affected business units in developing programs, policies, procedures, and training to implement related requirements and satisfy regulatory requirements; consults with the Legal team as needed; oversee technical reviews and testing to ensure they have been effectively implemented.
- Work closely with TDECU’ s Legal and Risk Management teams, retail branches and other business units to proactively identify, assess and remediate risk.
- Manage all aspects of TDECU’ s BSA regulatory examinations, makes necessary preparations for such exams or audits; coordinates responses to regulatory examiners and external auditors; implements action plans and presents reports to the Board of Directors that summarize results with recommended courses of action; interfaces with management and personnel regarding implementing remediation and monitor corrective action.
- Review any product, process, systems, or service whether new or revised that implicates any BSA/AML/OFAC or operations component prior to implementation. Manage changes in an environment of rapid growth and expansion into new products and services.
- Conduct periodic operational risk and control assessments using an enterprise-wide approach; develop the annual BSA/AML/OFAC compliance work plan/roadmap that reflects our highest risks that will be monitored by the BSA/AML compliance team.
- Manage the completion of the annual BSA-AML-OFAC Risk Assessment. Risks include but are not limited to those presented by the various types of accounts maintained at the Credit Union, the types of products and services offered, the various methods of opening accounts, the various types of identifying information available, and the size, location, and member base.
- Annually review the training process used to disseminate BSA and OFAC compliance-related information to affected business units; ensures our training program is appropriate for its size and operation; partners with Talent Services and Training and Development teams to develop and administer an effective compliance training program for employees and Board of Directors.
- Periodically review system records and operations to identify violations and program regulatory deficiencies.
- Complete required continuing education each year to retain compliance certifications and keep abreast on all regulatory requirements that relate to compliance, safety and soundness, information reporting, enforcement, civil and criminal penalties, administrative remedies, litigation, liability defenses and risk management.
- Identify potential areas of compliance vulnerability and risk; develops and implements corrective action plans for resolution of problems and provides general guidance on how to prevent situations in the future.
- Maintain a reporting system and provides reports on a regular basis, as directed or requested, to keep the Enterprise Risk Management (ERM) Committee of the Board and the Board of Directors informed of the performance and progress of the BSA Compliance Program.
- Accomplish department objectives by supervising staff, organizing, and monitoring work processes. Orient, provide training and opportunities to develop employees’ personal and professional growth goals. Oversees daily team operations by developing schedules, assigning and monitoring work progress and quality, gathering resources, enforcing productivity and accuracy standards, resolving and addressing any operational problems. Contributes to team effort by accomplishing results on an ongoing basis.
- Ensure all required regulatory reporting is completed in a timely, accurate and compliant manner, including the filing of Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR) to FinCEN, as well as FinCEN 314(a) and 314(b) procedures and reporting.
- Establish, maintain, and monitor an effective Customer Due Diligence and Enhanced Due Diligence program, as well as, High Risk rating and monitoring, to include initial and ongoing assessments, review, and analysis of unusual or suspicious account activity.
- Lead, motivate, develop, and inspire the BSA team to ensure optimal performance in meeting our goals.
- Provide timely, candid, and constructive performance feedback.
- Develop appropriate talent pool to ensure adequate bench strength and succession planning.
- Carry out supervisory responsibilities in accordance with our policies and applicable laws. Responsibilities include interviewing, hiring, and training employees; planning, assigning, and directing work; appraising performance; rewarding and disciplining employees; addressing complaints and resolving problems.
Supervise the daily activities of the department including, but not limited to, effective delegation of assignments, developing work schedules and providing necessary training. Monitors staff in daily tasks, operations, and quality control; ensures the organization of assigned areas of the department, coordinates available resources for maximum results.
- Bachelor' s degree or an at least five (5) years BSA compliance management experience in a financial institution. Certified Anti-Money Laundering Specialist (CAMS) required.
- A minimum of five (5) years BSA compliance management experience at a financial institution.
- Experience drafting policies and procedures, establishing and improving processes, implementing compliance management programs, and performing risk assessments.
- Experience working in a highly regulated environment and responding to inquiries and findings of regulators and auditors required.
- Experience reading, analyzing, and interpreting general business periodicals, professional journals, technical procedures, and laws and regulations required.
Knowledge, Skills, and Abilities
- Strong working knowledge of the regulatory framework within which financial institutions operate, including but not limited to knowledge of: Bank Secrecy Act, the Money Laundering Control Act, the Currency and Foreign Transaction Reporting Act, the Anti-Drug Act, the Annunzio-Wylie Anti-Money Laundering Act, the Money Laundering and Suppression Act of 1994, USA Patriot Act, and all applicable laws, rules, and regulations.
- Well-rounded knowledge of the credit union and/or banking industry, including all operational aspects, and the FFIEC Interagency BSA/AML Examination Manual.
- Excellent verbal and written communication skills; able to convey complicated advice and information in an understandable and engaging manner.
- Unquestioned integrity and excellent judgement.
- Excellent planning and organizational skills, including the ability to work independently on projects of high complexity with minimal supervision.
- Ability to maintain confidentiality and instill trust within the organization.
- Ability, availability, and willingness to work flexible hours to accomplish workload. During periods of peak demand and at other times, job will require a non-traditional workweek with extra hours including evening and/or weekend duties.
- Fast learner who thrives in a high-demand environment; works well under pressure.
- Ability to handle conflicts with diplomacy.
- Strong emotional intelligence.
- Capable of working successfully as a leader, an individual contributor, and on teams including diverse sets of personalities and skill levels.
- Ability to collaborate and work effectively across functions (including Legal, BSA, Talent Services, Fraud, Internal Audit, Operations, Retail, and Risk Management) in a fast-paced, high-volume, high-pressure environment.
- A business-focused, creative problem solver who is open to new ideas and new approaches.
- Willingness to continually learn and stay current on trends in the financial services industry.
- Expert level knowledge of relevant software including Microsoft Office, Word, Excel and Power Point.