BSA Officer

PayPal•San Jose, CA

About The Position

Advise on complex legal and regulatory compliance issues related to corporate structures. Influence executive-level decision-making through strategic insights and recommendations. Ensure the efficient operation of the organization's diverse entities by maintaining compliance with laws and regulations. Lead initiatives that promote effective governance and risk management across the organization. Own and administer the Bank's AML/CFT/OFAC program, including program design, customer risk profiles, risk assessments, internal controls, customer identification, due diligence, and trainings. Lead enterprise AML/CFT/OFAC risk assessment activities and drive risk-based controls to mitigate identified risks. Oversee financial crime monitoring and investigations governance, including alert management standards, case documentation, and escalation of emerging issues to senior management. Ensure timely, accurate regulatory reporting and program operations (e.g., SAR/CTR governance, exemptions, and supporting documentation standards). Establish and maintain a comprehensive training program for employees and Board members on AML/CFT/OFAC obligations Manage issue identification, tracking, and remediation tied to internal QA, independent testing/audit, and regulatory exams, with clear reporting to governance forums. Ensure effective oversight of any outsourced/affiliate-provided AML operations and technology, including performance metrics, quality controls, and SLA adherence (where applicable). Engage with internal audit and external regulators where required to represent the program. Design the initial AML/CFT risk assessment approach aligned to the proposed business model, products, delivery channels, and customer types, and ensure controls scale with growth. Develop first-line and second-line operating model, including staffing plan, role delineation, training plan, and vendor/technology implementation roadmap. Establish initial management and Board reporting packages (metrics, KRIs, issues, model/threshold changes, training completion, audit/exam readiness, and risk appetite thresholds / triggers). Coordinate independent testing/audit activities and ensure audit/exam findings are tracked, escalated appropriately, and remediated with effective corrective action. Provide clear governance updates to PPB management and Board committees on program effectiveness, key risks, and remediation status. 10+ years relevant experience and a Bachelor's degree OR Any equivalent combination of education and experience. Operate and continuously enhance the AML/CFT/OFAC program using a risk-based approach, including periodic updates to risk assessments, policies, procedures, and monitoring rules. Oversee ongoing operational processes (e.g., SAR/CTR program governance, exemptions, investigative standards, QA/quality control) and ensure consistent documentation and defensibility. Maintain and mature the training program for employees and the Board at least annually, and as risk, products, and regulations evolve. Lead continuous improvement through monitoring, QA, and independent testing readiness; ensure timely remediation of findings and sustained closure. Own program change management, including new products, new customer segments, technology changes, and material threshold/rule adjustments with governance approvals as required. Support development of the bank's risk culture by ensuring timely and relevant AML/CFT/OFAC trainings are delivered and completed. Education: Bachelor's degree in business, finance, economics, accounting, or a related discipline (or equivalent combination of education and experience). Experience (Director-level): 10+ years in BSA/AML/ CFT and financial crimes compliance within a bank or regulated financial institution, including demonstrated program leadership and governance experience. Demonstrated ownership of core AML/CFT/OFAC components (risk assessments, training, monitoring/controls, reporting governance, issue remediation). Strong ability to build and operationalize policies/procedures and lead cross-functional implementation across Compliance, Operations, Product, Technology, and Risk. Demonstrated ability to develop and deliver Board/Executive reporting and to drive remediation of audit/exam findings. CAMS (ACAMS) or equivalent AML Fraud / Financial Crimes certification. Prior experience as a designated BSA Officer/AML Officer for a bank or ILC (or as a deputy with clear accountability for program execution). Experience building or transforming AML programs in fast-growth, digital-first, or partner/embedded-finance environments (including vendor/tool selection and operating model design). Hands-on experience developing and delivering institution-wide AML/CFT/OFAC training programs, including Board training. Deep familiarity with SAR/CTR governance and documentation expectations, including CTR exemptions and investigative file quality standards.

Requirements

10+ years relevant experience and a Bachelor's degree OR Any equivalent combination of education and experience.
10+ years in BSA/AML/ CFT and financial crimes compliance within a bank or regulated financial institution, including demonstrated program leadership and governance experience.
Demonstrated ownership of core AML/CFT/OFAC components (risk assessments, training, monitoring/controls, reporting governance, issue remediation).
Strong ability to build and operationalize policies/procedures and lead cross-functional implementation across Compliance, Operations, Product, Technology, and Risk.
Demonstrated ability to develop and deliver Board/Executive reporting and to drive remediation of audit/exam findings.
Deep familiarity with SAR/CTR governance and documentation expectations, including CTR exemptions and investigative file quality standards.

Nice To Haves

CAMS (ACAMS) or equivalent AML Fraud / Financial Crimes certification.
Prior experience as a designated BSA Officer/AML Officer for a bank or ILC (or as a deputy with clear accountability for program execution).
Experience building or transforming AML programs in fast-growth, digital-first, or partner/embedded-finance environments (including vendor/tool selection and operating model design).
Hands-on experience developing and delivering institution-wide AML/CFT/OFAC training programs, including Board training.

Responsibilities

Advise on complex legal and regulatory compliance issues related to corporate structures.
Influence executive-level decision-making through strategic insights and recommendations.
Ensure the efficient operation of the organization's diverse entities by maintaining compliance with laws and regulations.
Lead initiatives that promote effective governance and risk management across the organization.
Own and administer the Bank's AML/CFT/OFAC program, including program design, customer risk profiles, risk assessments, internal controls, customer identification, due diligence, and trainings.
Lead enterprise AML/CFT/OFAC risk assessment activities and drive risk-based controls to mitigate identified risks.
Oversee financial crime monitoring and investigations governance, including alert management standards, case documentation, and escalation of emerging issues to senior management.
Ensure timely, accurate regulatory reporting and program operations (e.g., SAR/CTR governance, exemptions, and supporting documentation standards).
Establish and maintain a comprehensive training program for employees and Board members on AML/CFT/OFAC obligations
Manage issue identification, tracking, and remediation tied to internal QA, independent testing/audit, and regulatory exams, with clear reporting to governance forums.
Ensure effective oversight of any outsourced/affiliate-provided AML operations and technology, including performance metrics, quality controls, and SLA adherence (where applicable).
Engage with internal audit and external regulators where required to represent the program.
Design the initial AML/CFT risk assessment approach aligned to the proposed business model, products, delivery channels, and customer types, and ensure controls scale with growth.
Develop first-line and second-line operating model, including staffing plan, role delineation, training plan, and vendor/technology implementation roadmap.
Establish initial management and Board reporting packages (metrics, KRIs, issues, model/threshold changes, training completion, audit/exam readiness, and risk appetite thresholds / triggers).
Coordinate independent testing/audit activities and ensure audit/exam findings are tracked, escalated appropriately, and remediated with effective corrective action.
Provide clear governance updates to PPB management and Board committees on program effectiveness, key risks, and remediation status.
Operate and continuously enhance the AML/CFT/OFAC program using a risk-based approach, including periodic updates to risk assessments, policies, procedures, and monitoring rules.
Oversee ongoing operational processes (e.g., SAR/CTR program governance, exemptions, investigative standards, QA/quality control) and ensure consistent documentation and defensibility.
Maintain and mature the training program for employees and the Board at least annually, and as risk, products, and regulations evolve.
Lead continuous improvement through monitoring, QA, and independent testing readiness; ensure timely remediation of findings and sustained closure.
Own program change management, including new products, new customer segments, technology changes, and material threshold/rule adjustments with governance approvals as required.
Support development of the bank's risk culture by ensuring timely and relevant AML/CFT/OFAC trainings are delivered and completed.