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• Maintain and ensure that the Bank has risk-based policies, procedures and controls designed to ensure compliance with all applicable BSA/AML and Sanctions laws and regulations.
• Manage all interaction with regulatory or other government bodies as it pertains to BSA/AML and Sanctions compliance activities.
• Ensure the appropriate committees are in place to provide governance over BSA/AML and Sanctions.
• Perform annual BSA/AML and Sanctions risk assessments and modify when needed, such as the addition of new products, services or identified risks.
• Ensure the Credit Union has a Transaction Monitoring and Filtering Program that is consistent with the provisions of the NYS Department of Financial Services Section 504.
• Identify and document any potential weaknesses or gaps in the Credit Union's transaction monitoring program and identify and document appropriate remediation.
• Ensure findings and/or exceptions identified as a result of risk assessments, internal audits, compliance testing and/or regulatory examinations are documented and addressed in a timely manner by developing, approving and executing action plans to mitigate all findings and/or exceptions.
• Work with the Information Technology (IT) department to ensure testing is performed on new systems or enhancements to existing systems for transaction monitoring and sanctions screening software.
• Oversee supervision of the day-to-day BAU of the Investigators and Analysts, with respect to compliance with Transaction Monitoring procedures and prepayment alerts.
• Oversee management and monitoring of the Customer Information Program (CIP).
• Responsible for oversight of any KYC-related matters, including but not limited to: authority to close accounts, stop the on-boarding of new customer relationships or the opening of new accounts; approve all high-risk customers and any accounts associated with Politically Exposed Persons (PEPs)
• Review, approve and oversee filing of regulatory reports, including but not limited to CTRs, SARs, OFAC Blocked Property reports; OFAC reject and blocking letters; OFAC Voluntary Self Disclosure letters; and OFAC Annual Required Reporting as appropriate.
• Ensure that SARs & CTRs are completed and electronically filed with FinCEN on a timely basis.
• Provide monthly reports for submission to the CEO and Board of Directors.
• Establish, maintain and update the master Exemption List of members exempt from CTR reporting.
• Oversee execution process to ensure prompt response to 314(a) and 314(b) requests.
• Coordinate and administrate an up-to-date training program to ensure that all appropriate MCU employees receive required BSA and OFAC compliance training.
• Coordinate independent testing and review of the BSA/AML and OFAC Compliance Program, and the testing and validation of the automated systems utilized in the BSA/AML and OFAC Compliance Program.
• Manage all third-party systems used by the BSA Unit for the BSA/AML and OFAC Compliance Program.
• Ensure that Compliance Department conducts annual BSA/AML/OFAC Compliance training as well Annual Compliance Training for the entire Credit Union as applicable
• Oversee the process of annual reporting on Compliance-related performance criteria for use by the Credit Union in line with the BSA/AML/OFAC (Sanctions) Compliance-related performance.
• Manage and provide guidance to the BSA/AML and Sanctions Compliance Staff.
• Ensure that Credit Union Compliance staff have the required level of knowledge and technological support to carry out compliance responsibilities relating to all applicable 1aws, rules, regulations and policies of supervisory agencies and other relevant governmental agencies, with training to be performed at least annually, or otherwise more frequently as appropriate.
• Ensure that Senior Management and Board receive training and are knowledgeable about applicable US regulations, and compliance policies and procedures.
• Bachelor's Degree, Master's Degree or Juris Doctor Degree preferred.
• CAMS or similar equivalent certification.
• Minimum 10+ years of experience in BSA/AML and Sanctions at a financial institution, of which at least 3 years in a senior compliance managerial role.
• Strong knowledge of credit union or bank products and services.
• Excellent interpersonal and communication skills.
• Ability to interact with diverse groups in a professional manner.
• Must exercise good judgment and tact when applying knowledge of regulations and policies to a variety of situations.
• Excellent analytical skills.
• Excellent organizational and writing skills essential
• Ability to read and interpret laws and regulations.
• Proficiency in Microsoft for Windows Applications.
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