Compliance Bsa Manager - Bsa Compliance (Sanctions Governance) Dept-Firstbank Pr.

FirstBank Puerto Rico•San Juan, PR

2d•Hybrid

About The Position

At FirstBank PR, we strive to be a trusted advisor to our clients and our employees are the ones that ensure we deliver on our promise of excellence in personalized customer service. Our more than 3,100 employees in Puerto Rico, the Virgin Islands and Florida share a passion for excellent customer service. We are proud of our team because they are continuously surpassing our client’s expectations. The Compliance Manager of BSA/Sanctions Governance is a senior leader within the Compliance Department and serves as a key advisor and strategic partner to the BSA Officer. The role owns and manages BSA governance support, the OFAC Sanctions Program, AML and OFAC training, FinCEN 314(a), Section 311, regulatory reporting support, policy development, audit and examination responses, risk assessments, and cross-jurisdictional compliance activities across Puerto Rico, Florida, the U.S. Virgin Islands, and the British Virgin Islands. The role also leads enterprise-level compliance reporting cycles and supports the BSA Officer during independent testing cycles, FDIC examinations, CIAD reviews, and strategic regulatory reviews.

Requirements

A bachelor’s degree in business administration or related field is required.
Minimum of ten years of experience in financial institution compliance or a Juris Doctor.
Full bilingual proficiency in English and Spanish is required.
The role requires flexibility to travel across Puerto Rico, Florida, and the Virgin Islands.

Nice To Haves

Preferred experience in managing governance programs, enterprise risk assessments, audits/exams, and regulatory reporting cycles, including executive and Board-level deliverables.
CAMS and CGSS certifications are preferred.

Responsibilities

Manages the execution of governance, OFAC/Sanctions program, training, and FinCEN 314(a) and 311 responsibilities across all jurisdictions, in coordination with and under the direction of the BSA Officer.
Leads the execution of the OFAC and Sanctions Compliance Governance program, aligning enterprise policies, controls, and processes with U.S. and international expectations (OFAC, USA, FATF, FSC, FIA, UK).
Leads the review and update of policies under the BSA Officer’s scope, ensuring alignment with evolving regulations; prepares publication packages for executive and Board approval.
Oversees the accuracy and integrity of enterprise-wide BSA/AML and OFAC metrics and prepares near-final reports and dashboards for the BSA Officer’s review, ensuring they are complete, clear, and aligned with the expectations of senior management. These include Quarterly BSA/AML/OFAC Progress Reports and Board-level relevant SAR for the BOD Risk Committee, Enterprise Risk Management Committee, and regional BSA Committees summarizing BSA/AML/OFAC activity and strategic outcomes, biannual BSA Subcommittee presentations, and the BSA 5 Pillars Reports presented to the full Board twice per year.
Owns and executes the regulatory agenda and compliance reporting calendar, ensuring timely completion, quality control, and submission of all corporate reports.
Ensures timely completion of certification, attestations, and due diligence documentation (Wolfsberg Questionnaire, AML/CFT Questionnaire, Correspondent Banking Questionnaire, FED Annual KYC).
Drafts regulatory memoranda and formal compliance opinions by analyzing laws, regulatory guidance, and enforcement actions.
Documents internal interpretations of evolving regulations and support the rationale for policy and programmatic changes.
Supports geopolitical/special risk reviews (e.g., Russia/Ukraine, Venezuela, Special Measures), assessing institutional exposure and control readiness.
Leads the OFAC/Sanctions Risk Assessment annual process, including the creation of risk matrixes, coordination of institutional data, results analysis, and presentation to the Board Risk Committee and Senior Management. Gathers and validates data from business units across the Bank to ensure an accurate, data-driven risk profile.
Coordinates activities for the BSA/AML Risk Assessment by gathering and validating institutional data, compiling metrics, supporting analysis, and preparing management-ready reporting for review by the BSA Officer.
Annually reviews and updates the enterprise-wide Compliance Training Program and ensures alignment with regulatory expectations.
Designs, delivers, and manages classroom and online BSA/AML and OFAC compliance training programs for internal and external audiences.
Conducts training assignment reviews for over 3,000 employees across the organization, ensuring content matches role-based exposure and tracks completion of the training program and escalates non-compliance to BSA Officer and Human Resources.
Oversees the BVI-specific AML/CFT training curriculum, its assignment, and completion rate, and ensures full compliance with local regulatory requirements (FSC, FIA, UK).
Advises the BSA Officer on BVI jurisdiction-specific obligations, aligning multi-regional controls with global risk frameworks.
Serves as AML Deputy Officer for the BVI in the absence of the designated AML Officer, assuming responsibility for STR review, regulatory filings, and complaint resolution.
Serves as the Subject Matter Expert (SME) for audit activities related to OFAC/Sanctions and BSA governance areas; prepares responses to preliminary and final reports and leads the development and tracking of corrective action plans.
Meets with auditors and regulators, responds to information requests, clarifies procedures, and manages supporting documentation.
Leads support activities for FDIC exams under the BSA Officer’s direction, including onsite meetings, data coordination, issue tracking, and post-exam remediation support.
Supports implementation and testing of compliance systems and automation tools to improve efficiency and reduce manual effort.
Collaborates with IT and operation teams to ensure regulatory requirements are integrated into business workflows and system logic.
Supervises Compliance Specialists in the OFAC Governance Unit, overseeing sanctions screening, FinCEN 314(a)/311 reviews, and escalation management.
Serves as knowledge steward for governance, training, risk, and audit documentation; ensures institutional memory and continuity.
Provides support to the Compliance Director and/or BSA Officer in strategic and operational matters by assisting with key responsibilities when required.