BSA High Risk Team Lead

The BSA High Risk Team Lead is responsible for overseeing the Bank's enhanced due diligence (EDD) program and day-to-day monitoring of higher-risk customer relationships. This role leads a team of High Risk Analysts responsible for conducting transaction analysis, investigating unusual activity, and preparing comprehensive EDD reviews utilizing the Bank's AML monitoring systems. The Team Lead ensures accurate identification, investigation, escalation, and documentation of suspicious activity, including the review and filing of Suspicious Activity Reports (SARs) when appropriate.

The BSA High Risk Team Lead may also assist with oversight of Customer Identification Program (CIP) and Customer Due Diligence (CDD) exception monitoring processes. This includes reviewing CIP and CDD exceptions for completeness and accuracy, ensuring timely remediation of deficiencies, monitoring trends, escalating unresolved issues, and partnering with business lines to maintain compliance with regulatory requirements and the Bank's Customer Due Diligence Program.

In addition, the BSA High Risk Team Lead may serve as the primary BSA liaison for the Bank's Wealth Management program. Responsibilities include coordinating and scheduling customer reviews, conducting risk assessments, approving customer relationships, and ensuring adherence to the Bank's risk-based customer due diligence requirements.

The Team Lead collaborates closely with the BSA High Risk Officer and business-line partners to address issues identified during customer reviews, support regulatory examinations and internal audits, and promote the consistent application of BSA/AML policies and procedures. This position plays a key role in mitigating financial crime risk while ensuring compliance with applicable regulatory requirements and industry best practices.

• Manage, assign, and oversee high risk customer relationships, including required risk reviews, Enhanced Due Diligence (EDD) reviews, and periodic customer risk assessments.
• Lead and supervise a team of BSA High Risk Analysts, providing guidance, coaching, and technical support to ensure quality and timely completion of assigned work.
• Monitor team workflow, productivity, and case inventories to ensure compliance with established service level standards and regulatory requirements
• Review and assist with alerts, investigations, and cases requiring escalation or subject matter expertise.
• Coordinate and oversee EDD reviews, ensuring completion according to established schedules, procedural and regulatory requirements, along with providing recommendations for account retention or closure
• Review and analyze OFAC sanction alerts, CDD/EDD alerts, treasury management customer reviews, and other high risk activity
• Assess transaction patterns, identify red flags, and prepare risk-based analysis reports for escalation or decisioning.
• Ensure thorough and accurate customer due diligence (CDD) and enhanced due diligence (EDD) for elevated-risk customers
• Perform monitoring and analysis of transaction activity to identify unusual patterns (structuring, rapid balance shifts, abnormal cash volumes, wires, ACH, new accounts, etc.)
• Oversee and/or conduct SAR investigations, determining whether the activity meets filing thresholds and ensuring SARs are filed accurately and timely.
• Monitor and review 90-day SAR reviews as applicable
• Identify and implement efficiency opportunities and enhancements to the EDD component of the AML solution
• Assist High Risk Officer to establish, track and provide periodic reporting of key risk and key performance metrics along with High Risk Customer analysis reports identifying any deficiencies in the High Risk Team’s overall performance
• Provide direct support to the BSA High Risk team, by reviewing cases and alerts requiring input or assistance, and monitor workflow and production
• Maintain a good working knowledge of OFAC, foreign customers' identifying documents and Beneficial Ownership Certification requirements
• Manage criminal subpoena reviews and escalate concerns to BSA Officer and/or High Risk Officer
• Serve as the primary BSA contact for the Wealth Management team
• Meet with Wealth Management staff on an ongoing basis
• Assist the BSA High Risk officer in developing, tracking, and reporting key risk indicators (KRIs), key performance indicators (KPIs), and trend analysis related to the High Risk Customer Program.
• Collaborate across compliance and risk teams, including corporate security and financial intelligence units, especially when dealing with complex risk scenarios.
• Prepare written analyses, summaries, and reports for escalation
• Develop and deliver BSA/AML training, especially focusing on identifying higher-risk customers and behaviors
• Oversee the identification, review, tracking, and resolution of CIP exceptions, including missing or incomplete customer identification information, documentary verification deficiencies, and regulatory documentation requirements.
• Monitor and review CDD exceptions to ensure accurate customer risk ratings, completion of required due diligence information, Beneficial Ownership compliance, and timely resolution of outstanding deficiencies.
• Track CIP and CDD exception trends, identify systemic issues, and provide reporting and recommendations to management regarding process improvements and risk mitigation strategies.
• Compliance Training:  Participate in all required compliance training, including Bank Secrecy Act/anti-money laundering training, as well as internal and external training programs, online training, meetings, and seminars/conferences, etc.
• Provide timely advice and recommendations to senior management on emerging BSA related issues.  Work with corporate compliance or operational groups to develop new procedures when law or regulation mandates new BSA initiatives
• Have a team-oriented mentality and the ability to influence people and generate a productive work environment
• Perform check-ins along with staff and coordinate with High Risk Officer regarding goals for staff, including annual performance reviews
• Approve timecards as needed
• Other Duties: This job description is not designed to cover or contain a comprehensive list of activities, duties or responsibilities that are required of the employee. Other duties, responsibilities, and activities may change or be assigned at any time with or without notice.

• High School diploma or equivalent, bachelor’s degree in criminal justice, economics, or accounting preferred.
• A minimum of 4 years prior BSA experience or similar banking experience required
• Strong analytical, research, judgmental and communication skills
• Ability to provide software training or transaction analysis as needed to others

Required Skills

• CAMS, CBAP, or CAFP certification
• Maintain continuing education with CAMS, CBAP, or CAFP certification
• Possess strong skills in Word, Excel and PowerPoint
• Accurate, detail-oriented, organized and possess strong time management skills
• Must be reliable and committed to the job and have a genuine desire to learn
• Must have analytical skills for understanding transactional activity, excellent verbal communication skills and possess excellent writing skills
• Experience reviewing Trust, Wealth Management, Private Banking relationships

Preferred Skills

• Accurate, detail-oriented, organized, and a skilled time manager
• Previous exposure to current BSA/AML software systems

• Must be able to pass a criminal background & credit check.

FLSA Status: Exempt

Supervisory Responsibility

This position manages employees and is responsible for the coaching, development, and performance management of those employees.

Working Environment and Physical Demands

• This position operates in a professional office environment. The role routinely uses standard office equipment such as computers, phones, copy machines, and printers.
• Physical requirements: sedentary, climbing, standing, stooping, or typing
• This position may require up to 5% travel.

Position Type

This is a full-time position that requires scheduled flexibility to work evenings and weekends as needed.

Other

We are an Equal Opportunity Employer and do not discriminate against any employee or applicant for employment because of race, color, sex, age, national origin, religion, sexual orientation, gender identity and/or expression, status as a veteran, and basis of disability or any other federal, state or local protected class.

Reasonable accommodation may be made to enable individuals with disabilities to perform the essential functions.