Director, Financial Crimes Compliance

Upstart

9h•$201,200 - $278,500•Remote

About The Position

As the Director, Financial Crimes Compliance, you will play a key role in providing guidance in supporting Upstart Bank’s FCC program. If you are excited by designing scalable compliance solutions, and building trusted relationships across a fast-moving fintech, this role is for you. How you’ll make an impact: Develop, implement, and maintain Upstart’s Enterprise-Wide BSA/AML/OFAC Compliance Program, ensuring it remains aligned with regulatory requirements, evolving financial crime risks, and the company’s risk appetite. Lead enterprise-wide BSA/AML and sanctions risk assessments, identify emerging risks, and establish risk-based controls, monitoring frameworks, and governance processes to mitigate financial crime exposure. Present regular reporting to the Board of Directors, executive leadership, and risk committees, including risk assessment results, program effectiveness metrics, key risk indicators (KRIs), regulatory developments, and remediation progress. Manage a comprehensive Customer Identification Program (CIP), Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) framework, including oversight of customer risk rating methodologies and ongoing monitoring activities. Oversee the review and management of high-risk customer relationships, including onboarding decisions, periodic reviews, escalation processes, and recommendations regarding customer exits or relationship terminations. Provide senior-level oversight and strategic guidance for complex investigations involving unusual activity, suspicious activity reporting (SAR), and regulatory reporting obligations. Serve as the primary point of contact for regulatory examinations, independent audits, and compliance reviews related to BSA/AML and sanctions compliance, ensuring timely and effective remediation of identified issues. Partner with Product, Engineering, Operations, Legal, and Risk teams to design scalable financial crime controls for new products, including consumer deposit and lending products. Monitor regulatory developments and provide guidance on BSA, AML, sanctions, fraud, and related financial crime compliance requirements impacting Upstart’s business.

Requirements

Bachelor’s degree in Business, Finance, Accounting, Criminal Justice, Law, or a related field.
10+ years of experience leading BSA/AML compliance programs within a bank, credit union, fintech, or other regulated financial institution.
Deep knowledge of the Bank Secrecy Act (BSA), USA PATRIOT Act, OFAC sanctions requirements, FinCEN guidance, Know Your Customer (KYC) ,Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Suspicious Activity Reporting (SAR) requirements.
Experience completing BSA/AML/OFAC risk assessments and using the results to build, enhance, and manage BSA/AML compliance programs supporting consumer deposit products and lending products.
Experience overseeing high-risk customer programs, customer risk rating methodologies, enhanced due diligence reviews, and customer relationship termination decisions.
Demonstrated experience leading regulatory examinations, independent audits, and remediation efforts related to BSA/AML and sanctions compliance.
Experience presenting financial crime compliance matters, risk assessments, and program metrics to senior executives, risk committees, and Boards of Directors.
Knowledge of consumer banking regulations applicable to deposit and lending products.

Nice To Haves

CAMS (Certified Anti-Money Laundering Specialist), CAFP (Certified AML and Fraud Professional), CRCM, or comparable compliance certification.
Experience serving as a BSA Officer, Deputy BSA Officer, or senior financial crimes compliance leader within a highly regulated financial institution.
Experience building and scaling AML transaction monitoring, sanctions screening, customer risk scoring, and implementing case management programs.
Experience using AI powered solutions to scale and automate BSA program work
Knowledge of digital banking, fintech, embedded finance, or marketplace lending business models.
Experience implementing technology-enabled compliance solutions, automated controls, and risk monitoring frameworks.
Experience working directly with federal and state banking regulators, including OCC, FDIC, Federal Reserve, CFPB, FinCEN, or state banking agencies.
Familiarity with fraud risk management frameworks and the intersection of fraud and AML compliance programs.

Responsibilities

Develop, implement, and maintain Upstart’s Enterprise-Wide BSA/AML/OFAC Compliance Program, ensuring it remains aligned with regulatory requirements, evolving financial crime risks, and the company’s risk appetite.
Lead enterprise-wide BSA/AML and sanctions risk assessments, identify emerging risks, and establish risk-based controls, monitoring frameworks, and governance processes to mitigate financial crime exposure.
Present regular reporting to the Board of Directors, executive leadership, and risk committees, including risk assessment results, program effectiveness metrics, key risk indicators (KRIs), regulatory developments, and remediation progress.
Manage a comprehensive Customer Identification Program (CIP), Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) framework, including oversight of customer risk rating methodologies and ongoing monitoring activities.
Oversee the review and management of high-risk customer relationships, including onboarding decisions, periodic reviews, escalation processes, and recommendations regarding customer exits or relationship terminations.
Provide senior-level oversight and strategic guidance for complex investigations involving unusual activity, suspicious activity reporting (SAR), and regulatory reporting obligations.
Serve as the primary point of contact for regulatory examinations, independent audits, and compliance reviews related to BSA/AML and sanctions compliance, ensuring timely and effective remediation of identified issues.
Partner with Product, Engineering, Operations, Legal, and Risk teams to design scalable financial crime controls for new products, including consumer deposit and lending products.
Monitor regulatory developments and provide guidance on BSA, AML, sanctions, fraud, and related financial crime compliance requirements impacting Upstart’s business.

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!)