Crypto/Payments Business Enhanced Due Diligence Associate

First Citizens Bank•Phoenix, AZ
•Hybrid

About The Position

This hybrid role is available only in Raleigh, Phoenix, Dallas, Austin, or Chicago. The associate joins First Citizens Innovation Bank’s Enhanced Due Diligence team and conducts enhanced due diligence on cryptocurrency-related clients who may pose money laundering, terrorist financing, sanctions, or reputational risks. The role supports legal and regulatory requirements and leads reviews of prospective and existing clients to ensure compliance with the bank’s enhanced due diligence requirements. The associate serves as an expert on cryptocurrency BSA/AML compliance for the Commercial Bank, engaging with relationship teams, clients, risk professionals, management, and other internal or external constituents. The position communicates the rationale for EDD decisions, stays current on cryptocurrency developments and policy changes, and helps improve processes and controls. It also involves educating others about the cryptocurrency ecosystem, developing processes, and coaching colleagues. The associate may manage others’ work and mentor associates.

Requirements

  • Bachelor’s degree and at least 4 years of EDD review experience in FinTech, banking, KYC compliance, or risk management; alternatively, a high school diploma or GED and at least 8 years of experience.
  • Comprehensive understanding of blockchain technology, its core principles, and applications.
  • Strong understanding of anti-money-laundering risks associated with cryptocurrency, payments, and FinTech business models.
  • Knowledge of international and regional financial crime risks, including AML, counter-terrorism financing, fraud, and prevention and mitigation controls.
  • Understanding of regulatory frameworks applicable to financial institutions, particularly FinCEN regulations, FFIEC guidelines, the Bank Secrecy Act, and the U.S. PATRIOT Act.
  • Ability to assess compliance programs, processes, and controls.
  • Ability to collaborate with peers and leaders to achieve common goals.
  • Effective written and oral communication skills with all organizational levels and bank clients, in person and by telephone.
  • Ability to work independently, take initiative, and communicate effectively in writing and verbally.
  • Strong analytical, research, organizational, and project management skills.
  • Flexibility to learn new topics and handle change and deadlines in response to newly identified risks or process changes.
  • Strong understanding of Microsoft Office applications and ability to learn internal systems quickly.

Nice To Haves

  • Experience in KYC compliance at a large financial institution or crypto MSB/VASP.
  • A BA in Finance, Economics, Legal Studies, or Criminal Justice.
  • ACAMS, Certified Cryptoasset AFC Specialist (CCAS), or Certified Fraud Examiner certification.

Responsibilities

  • Conduct thorough enhanced due diligence reviews of new and existing clients in the broader cryptocurrency ecosystem.
  • Analyze client profiles, business activities, ownership structures, risk factors, transactions, and account activity for money laundering, terrorist financing, sanctions, fraud, and other financial crime risks.
  • Review and verify client documentation, including identification documents, business licenses, financial statements, and transaction records, for accuracy and completeness of KYC information.
  • Assist clients and prospects in establishing appropriate controls to meet the bank’s requirements.
  • Ensure compliance with applicable EDD, KYC, BSA, sanctions, and AML requirements, industry standards, internal policies, and best practices.
  • Document and maintain accurate due diligence records, findings, decisions, and supporting documentation.
  • Serve as a subject matter expert and primary point of contact for Commercial Bank relationship teams on high-risk, complex, and cryptocurrency reviews.
  • Identify prospects and existing clients whose business models may carry increased AML risk and help them meet the bank’s high-risk requirements.
  • Identify, assess, communicate, and help control existing and emerging risks.
  • Partner with Compliance, Internal Audit, and other departments on examinations and audit requests; manage action-plan execution and implementation.
  • Identify opportunities to automate or streamline quality and compliance efforts.
  • Develop and report risk-tolerance metrics and provide ongoing reporting on the high-risk sector pipeline to senior management.
  • Communicate with internal stakeholders, relationship managers, and business units to address EDD queries and resolve issues.
  • Assess prelaunch or emerging business models against internal EDD and approval requirements.
  • Share insights and provide support, training, and guidance on policies, procedures, and best practices across cross-functional teams.
  • Stay current with cryptocurrency developments and policy changes, and improve processes and controls.
  • Educate colleagues and clients on the cryptocurrency ecosystem; develop processes and coach others.
  • May manage the work of others and mentor associates.

Benefits

  • The company offers a competitive benefits program; specific benefits are described on its benefits website.
  • Total compensation for some roles may include variable incentives, bonuses, benefits, and/or other awards.
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