BSA High Risk Analyst

MidCountry Bank•St. Cloud, MN

1d•$80,000 - $85,000•Hybrid

About The Position

The BSA High Risk Analyst is responsible for the oversight, administration, and ongoing monitoring of the Bank’s high-risk customer portfolio, with primary responsibility for the marijuana banking program. This position supports the Bank’s compliance with all applicable laws and regulations related to Bank Secrecy Act (BSA), Anti-Money Laundering (AML), Office of Foreign Assets Control (OFAC), FinCEN guidance, and internal policies and procedures. The analyst performs enhanced due diligence (EDD), transaction monitoring, risk assessments, suspicious activity investigations, and periodic reviews for high-risk customers and business types. This role works closely with Retail Banking, Treasury Management, Deposit Operations, Lending, Compliance, and Executive Management to ensure high-risk relationships are appropriately onboarded, monitored, and managed.

Requirements

High School diploma
4-6 years of experience in BSA/AML compliance within a financial institution.

Nice To Haves

Bachelor’s degree in finance, accounting, criminal justice, business or related field
Experience managing or supporting a marijuana banking program

Responsibilities

Administer and oversee the Bank’s marijuana banking program, including onboarding, due diligence, monitoring, and ongoing compliance reviews.
Conduct enhanced due diligence for marijuana-related businesses (MRBs), including: Beneficial ownership verification, State licensing validation, Business structure and ownership reviews, Site visit coordination and documentation, Source of funds analysis, Financial activity analysis.
Monitor customer activity for consistency with expected business operations and documented cash flow.
Review cash activity, ACH transactions, wires, RDC activity, and account patterns for suspicious or unusual activity.
Maintain marijuana banking customer files and ensure documentation remains current and complete.
Prepare and maintain required reporting related to MRB customers, including Suspicious Activity Reports (SARs) and any marijuana-specific SAR narratives.
Coordinate periodic reviews and risk rating updates for marijuana banking relationships.
Monitor state and federal regulatory developments impacting marijuana banking activities.
Perform enhanced due diligence reviews for other high-risk customer categories, including but not limited to: Money Services Businesses (MSBs), Cash-intensive businesses, Nonprofit organizations, ATM operators, Cryptocurrency-related customers, Third-party payment processors, Foreign businesses or individuals, High-risk legal entities.
Conduct periodic account reviews and ongoing monitoring activities.
Analyze transactional activity to identify unusual patterns, structuring, fraud indicators, or potential money laundering activity.
Assist with customer risk rating reviews and updates.
Investigate alerts generated through transaction monitoring systems.
Prepare, document, and file Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) as needed.
Support the Bank’s Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) programs.
Assist with regulatory examinations, internal audits, and independent BSA audits.
Maintain accurate and organized records supporting investigative decisions and compliance activities.
Participate in the development and enhancement of BSA policies, procedures, and monitoring processes.
Assist with training bank staff on high-risk customer identification, marijuana banking requirements, and fraud red flags.
Partner with frontline staff during onboarding of high-risk relationships.
Provide guidance to business lines regarding account restrictions, monitoring expectations, and risk mitigation strategies.
Escalate significant compliance concerns, suspicious activity, or policy exceptions to BSA leadership.
Participate in committees or working groups related to fraud, compliance, and operational risk.