AML/BSA/OFAC Risk Program Manager (Special Risk)

About the Role

This position involves designing, implementing, and managing customized AML/BSA and OFAC risk monitoring programs for complex customer types designated as Special Risk. These include Merchant Acquiring Independent Sales Organizations (ISOs), Payment Facilitators (PayFacs), Third Party Payment Processors (TPPPs), and Money Service Businesses (MSBs). You will partner with business lines to define risk mitigation requirements and controls, perform onsite reviews, and participate in executive risk committees. A key aspect of this role is monitoring regulatory and legal requirements for higher-risk verticals such as online gaming/gambling, digital assets, and money services. You will also manage high-profile AML/BSA program initiatives, including the BSA enterprise risk assessment, and regularly communicate findings to senior management.

Job Duties and Responsibilities

• Manage enhanced due diligence activities for new and potential ISO, PayFac, TPPP, and MSB clients to mitigate risk exposure for the Bank.
• Serve as the central point of contact for line-of-business and all Special Risk customer-related matters.
• Develop AML/BSA guidelines for merchant ISO businesses and related policies and procedures.
• Apply knowledge of assigned specialty risk areas (e.g., online gaming/gambling, digital assets, money services) to customer due diligence and oversight.
• Conduct site visits of existing and potential customers with the line of business.
• Manage the collection, review, and approval of all documentation for risk mitigation and regulatory compliance.
• Manage all Requests for Information (RFIs) related to special risk customer types.
• Apply knowledge of bankcard payment operator network (e.g., Visa, MasterCard, AMEX, Discover) rules, standards, and practices related to acquirer due diligence, including processor operating systems and high-risk merchant categories and transactions.
• Provide guidance and respond to daily inquiries from peers and the first line of defense regarding new or changing regulations impacting payment systems and merchant acquiring.
• Conduct and complete BSA-related reviews and testing of controls directly with the line of business and clients.
• Create formalized reporting of test results and recommendations for remediation.
• Prepare key information for management presentations regarding Special Risk customers and provide ongoing training to the line of business.
• Assist management with independent reviews and federal examinations, interacting with auditors/examiners on Special Risk relationships, control testing, and risk assessments.
• Design, generate, and complete management reports as assigned.
• Work with management to implement new initiatives, improve current processes, and assist with special projects.
• Assist Senior Management with creating best-in-class risk and control testing for integration into the risk assessment.
• Attend assigned AML/BSA training seminars and stay aware of regulatory developments and industry trends.
• Operate in full compliance with internal policies, procedures, and applicable regulations (including Bank Secrecy Act/Anti-Money Laundering requirements).
• Adhere to confidentiality policy, code of ethics, and all policies and procedures related to Compliance laws, regulations, and best practices.
• Maintain awareness of risk within the functional area and report any known or suspected violations.
• Perform other related duties as required.

Qualifications

Minimum Education:

• Bachelor's degree or an equivalent combination of education and experience.

Minimum Experience:

• Six (6) or more years of job-related experience with emphasis on BSA Compliance, enhanced due diligence, risk assessments, regulatory compliance, and risk policy/procedures as they relate to merchant ISOs and Third Party Payment Processors.

Required Knowledge, Skills, & Abilities:

• Strong knowledge of the merchant acquiring business and BSA/AML/OFAC compliance through previous work experience.
• Strong knowledge of applicable regulations and regulatory bodies for BSA/AML/OFAC and merchant/card services.
• Strong knowledge of potential high-risk verticals within ISO merchants (e.g., gambling and gaming).
• Strong knowledge of card network rules applicable to merchant acquiring.
• Strong knowledge of risk and control testing and risk assessments.
• Excellent judgment and ability to handle issue resolution professionally and consistently.
• Ability to confidently facilitate team discussions and communicate business messages.
• Strong listening skills and a positive communicator.
• Skill in writing reports, white papers, and business correspondence.
• Proficiency using applicable programs, systems, and databases required to assess risk and controls.
• Proficiency using Microsoft Office software products.

Benefits

• (Benefits not explicitly detailed in the provided text, but implied through the role's contribution to branch success and team development.)