Sanctions

Comun•New York, NY

About The Position

We are looking for a highly motivated Compliance Manager with deep experience in BSA, AML, and Sanctions to join our team at Común. This role is critical in ensuring our organization meets and exceeds all regulatory expectations. As the Compliance Manager covering BSA, AML, and Sanctions, you will oversee the design, implementation, and maintenance of Comun’s BSA/AML compliance program. Your primary responsibility will be to ensure adherence to applicable regulations, including the Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, and OFAC sanctions.

Requirements

Experience: 3–5 years in a compliance role, specifically within the Fintech or high-growth financial services sector.
Audit Background: Proven experience navigating the audit lifecycle, from initial discovery and information gathering to remediation.
Communication: Ability to translate complex regulatory jargon into plain English for non-compliance stakeholders.
Education: Bachelor’s degree required
An interest in serving an underserved community :)

Nice To Haves

Technical Prowess: Experience with SQL, Python or using AI/Machine Learning tools for data analysis is a significant plus.
Certification: CAMS (Certified Anti-Money Laundering Specialist) or equivalent certification is highly preferred.

Responsibilities

Oversee BSA/AML Program: You will develop new BSA/AML policies, procedures, and controls, as needed, and review existing documentation and controls to assess effectiveness and enhance as required to adhere to the latest regulatory expectations, industry best practices, and emerging risks.
Risk Assessment and Monitoring: You will conduct the annual BSA/AML compliance risk assessment to identify money laundering and financial crime risk across Comun’s operations and lead the remediation of any gaps. You will oversee the transaction monitoring systems and the review of suspicious activities to ensure that identified risks are properly mitigated. You will lead and monitor the completion of Unusual Activity Reports (UARs), customer due diligence (CDD), and enhanced due diligence (EDD) processes. You will build controls and procedures from scratch where needed, and regularly assess existing internal controls and procedures to improve the effectiveness of the BSA/AML program and respond to emerging risks.
Audit/Exam Management: You will coordinate responses to BSA/AML-related audit and regulatory inquiries and act as a primary point of contact regarding BSA/AML matters.
Internal Compliance Training: Review and implement compliance training for Comun staff on relevant BSA/AML requirements. You will promote a culture of compliance across Comun and help employees understand their role in maintaining a robust and effective BSA/AML program.
Compliance Oversight and Reporting: You will provide regular reports to senior management regarding the effectiveness of the BSA/AML program, regulatory developments, and compliance trends. You will serve as a key advisor to senior leadership on matters related to financial crimes and risk mitigation strategies. You will serve as the main point of contact for our partner bank reporting.
BSA/AML Operations: You will oversee the agents performing BSA/AML operations, including manual reviews, transaction monitoring, and UARs. You will serve as the escalation point for all matters arising from this team. You will ensure policies and procedures are adhered to by building and conducting appropriate training and quality assessments.
Overall Compliance Program Ownership: Though you will be responsible for the BSA/AML program primarily, you will be supporting the Head of Compliance on other areas of the Compliance program (CMS, Regulation E, Compliance Committee meetings) as needed.