Compliance Manager, BSA/AML Program

Upstart

7h•$115,800 - $160,100•Remote

About The Position

Upstart's Bank Secrecy Act/Anti-Money Laundering Compliance team is responsible for designing, implementing, and overseeing the company's enterprise BSA/AML Program, Customer Identification Program (CIP), Customer Due Diligence (CDD), sanctions, and suspicious activity compliance programs. We partner closely with Product, Engineering, Operations, Legal, Fraud, and Enterprise Risk to ensure our products and services are built on a strong foundation of regulatory compliance and effective risk management. We build scalable, risk-based programs that evolve alongside our products and regulatory expectations. As the Compliance Manager, BSA/AML Program at Upstart, you will serve as a BSA/AML subject matter expert for Upstart Bank’s secured and unsecured lending products and support the development of new deposit products. Using a risk-based approach, you will evaluate changes to identify risks, develop controls, and measure ongoing performance of changes to ensure products and services are implemented within a strong compliance framework.

Requirements

Bachelor's degree or equivalent practical experience.
7+ years of experience in BSA/AML compliance, financial crimes compliance, or a related Risk or Compliance role within a bank or other regulated financial institution.
Experience implementing and managing customer onboarding processes including identity verification, customer due diligence (CDD), enhanced due diligence (EDD), sanctions screening, and ongoing monitoring processes.
Working knowledge of regulatory requirements, including the Bank Secrecy Act (BSA), USA PATRIOT Act, and Customer Due Diligence Rule, and BSA/AML risks associated with deposit products
Experience developing and delivering AML risk assessments, KRIs/KPIs, and management reporting while leading cross-functional compliance initiatives.
Strong organizational, analytical, communication skills.
Ability to identify gaps in policies and procedures and drive resolution and closure
Experience in audit and exam readiness, including evidence gathering, testing and monitoring, addressing findings, responding to requests.

Nice To Haves

Certified Anti-Money Laundering Specialist (CAMS), Certified AML and Fraud Professional (CAFP), or equivalent certification.
Experience supporting deposit products, including high-yield savings accounts, certificates of deposit, brokered deposits, or similar banking products.
Familiarity with implementing BSA/AML tools for transaction monitoring, case management, and customer screening
Experience working with examiners, auditors, and other third-parties.
Knowledge of regulatory change management and implementing new BSA/AML requirements.
Ability to investigate complex compliance issues, perform root cause analysis, and provide guidance to support issue resolution

Responsibilities

Lead the design, execution, and continuous improvement of BSA/AML, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), transaction monitoring, and sanctions screening processes for secured lending, unsecured lending, and deposit account products.
Serve as a BSA/AML Compliance advisor for deposit product initiatives, partnering with Product, Legal, Operations, Engineering, and Enterprise Risk throughout product development and implementation.
Develop and manage BSA/AML compliance initiatives, including new deposit product launches, regulatory enhancements, and control improvements.
Administer ongoing customer due diligence and enhanced due diligence programs for deposit accounts in alignment with Upstart's Customer Identification Program (CIP), Red Flags Program, and BSA/AML compliance procedures.
Evaluate relevant risks and typologies to develop appropriate transaction monitoring rules and efficient investigations processes
Monitor evolving regulatory requirements, including FinCEN guidance, OFAC sanctions, and FFIEC BSA/AML examination expectations, to translate regulatory changes into scalable business processes and controls.
Develop key risk indicators (KRIs), key performance indicators (KPIs), and management reporting that provide actionable insights into BSA/AML program effectiveness.
Translate regulatory requirements and risk trends into clear recommendations for business stakeholders and senior leadership.
Drive remediation efforts for examination, audit, monitoring, and testing findings while strengthening the overall BSA/AML compliance control environment.

Benefits

Competitive compensation, including base pay, bonus opportunities, and annual equity grants that vest quarterly
Retirement benefits to help you plan for the future, including a 401(k) or Group Retirement Savings Plan with a company match of $2 for every $1 contributed, up to $15,000 annually (USD in the US, CAD in Canada)
Employee Stock Purchase Plan (ESPP) with discounted stock purchase options for eligible employees (US only)
Comprehensive health coverage designed to support you and your family, including medical, dental, vision, and wellness resources for US and supplemental health coverage for Canada.
Health Savings Account contributions from Upstart for eligible plans (US only)
Income protection benefits, including life insurance and disability coverage for added financial security
Paid time off, sick leave, and company holidays, in line with local requirements
Paid family and parental leave to support caregiving and major life moments (duration varies by country)
Family-centered benefits to support fertility, parenthood, and caregiving needs
Employee Assistance Program (EAP) offering mental health support and life-centered resources
Financial wellness resources, including access to financial planning tools and a financial concierge service (US Only)
Annual wellness allowance to support your physical and emotional well-being and personal development, based on what matters most to you
Annual productivity allowance to invest in relevant tools and resources you need to do your best work, no matter where you work from
Connection and community through team events, all-company updates, and employee resource groups (ERGs)
Onsite perks, including catered lunches and fully stocked micro-kitchens when working from one of our offices in the Bay Area, Austin, Columbus, and New York City (opening Summer 2026!)