FCRM CIP, CDD, EDD and KYC Program Manager

KeyBank • Brooklyn, OH

1d • Hybrid

About The Position

The Senior Compliance Officer serves as the enterprise subject matter expert and senior second-line compliance authority for the Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Know Your Customer (KYC) frameworks. The role provides enterprise-wide governance, oversight, credible challenge, and strategic guidance to help ensure related processes, procedures, standards, controls, systems, data, and supporting documentation are appropriately designed, implemented, maintained, and operating effectively.

The role partners across the first, second, and third lines of defense to identify regulatory risk, assess control coverage and design, resolve complex matters, drive sustainable remediation, and promote consistent execution across applicable legal entities, businesses, products, channels, and customer segments. It may lead and supervise compliance professionals and lead cross-functional initiatives. The position is hybrid, with an in-office presence of three or more days.

Requirements

• Bachelor’s degree or equivalent combination of education and relevant experience.
• Extensive experience in BSA/AML, financial crimes compliance, regulatory compliance, KYC operations, risk management, Legal, Internal Audit, or a related discipline within a financial institution.
• Deep knowledge of CIP, CDD, EDD, beneficial ownership, customer risk rating, customer lifecycle management, and risk-based compliance program expectations.
• Demonstrated ability to interpret regulatory requirements and translate them into enterprise policies, standards, controls, governance routines, and practical business guidance.
• Experience evaluating complex processes and control environments, identifying systemic risk, and influencing sustainable corrective action.
• Strong executive communication, facilitation, negotiation, and written documentation skills, including the ability to explain complex risk matters clearly and concisely.
• Demonstrated ability to lead cross-functional initiatives, influence senior stakeholders, and provide credible challenge in a complex, highly regulated environment.

Nice To Haves

• Seven or more years of federal law enforcement or U.S. Intelligence Community experience; veterans are encouraged to apply.
• Three or more years of management experience.
• Extensive experience in financial crimes investigations.
• Advanced degree in law, business, finance, risk management, criminal justice, or a related field.
• Professional certification such as CAMS, CFE, CRCM, CFCS, or a comparable compliance or financial crimes credential; CAMS certification is preferred.
• Experience with large or complex financial institutions, multiple lines of business, enterprise transformation, regulatory remediation, or direct regulatory examination engagement.
• Knowledge of data governance, technology controls, automation, and systems supporting customer onboarding and lifecycle management.

Responsibilities

• Serve as the enterprise subject matter expert for CIP, CDD, EDD, KYC, beneficial ownership, customer risk rating, customer lifecycle management, and related regulatory requirements and industry practices, including reviewing, approving, or denying cases, records, and escalations.
• Execute risk oversight activities in accordance with the FCRM governance framework, related standards, and requirements.
• Provide second-line oversight and credible challenge of enterprise processes, procedures, controls, systems, tools, data, and operational practices supporting customer identification, verification, due diligence, risk classification, enhanced review, onboarding, periodic review, trigger-based review, and customer exit.
• Interpret applicable laws, rules, regulatory guidance, examination expectations, and enforcement themes; assess enterprise impact; and translate requirements into policies, standards, control expectations, and implementation guidance.
• Own or provide authoritative review and approval of enterprise CIP, CDD, EDD, and KYC policies and standards, and oversee governance of supporting first-line procedures and job aids.
• Evaluate control design and operating effectiveness, including whether execution is consistent, evidenced, and sustainable across the enterprise.
• Identify gaps, emerging risks, inconsistent practices, control weaknesses, and potential regulatory exposure; communicate risk and require timely corrective action or formal risk acceptance as appropriate.
• Support enterprise risk assessments, including BSA/AML and regulatory compliance risk assessments, risk and control self-assessments, customer risk methodologies, and topical assessments related to CIP, CDD, EDD, and KYC.
• Define and monitor risk appetite, risk tolerance, key risk and performance indicators, control metrics, quality results, exceptions, backlogs, aging, and other program-health information.
• Review and challenge business process risk identification and changes involving products, services, customer journeys, delivery channels, acquisitions, integrations, third parties, or other matters that may affect CIP, CDD, EDD, or KYC obligations.
• Provide senior compliance guidance on complex, high-risk, novel, or escalated customer matters, including high-risk customer acceptance, due diligence sufficiency, beneficial ownership, documentation exceptions, risk-rating disputes, remediation, restriction, and exit considerations.
• Partner with Legal, BSA/AML leadership, sanctions, business compliance, operations, technology, data, model risk, fraud, privacy, third-party risk, Internal Audit, and independent testing teams to promote an integrated and consistent control environment.
• Oversee, develop, or credibly challenge quality assurance, compliance monitoring, independent testing, internal audit, and regulatory examination activities; assess results, identify systemic themes, and track management response.
• Provide subject matter leadership for regulatory examinations, audits, inquiries, and information requests, including preparing narratives, evidence, issue responses, and presentations to senior management or governance committees.
• Oversee issue identification, severity assessment, root-cause analysis, corrective-action design, validation readiness, risk acceptance, and sustainable closure for CIP, CDD, EDD, and KYC matters.
• Provide compliance oversight of data governance, data lineage, data quality, record retention, system functionality, automated decisioning, rules, models, and technology changes supporting the KYC lifecycle.
• Establish enterprise training requirements and provide or oversee targeted training, communications, implementation materials, and subject matter support for affected employees and stakeholders.
• Prepare and present reporting on risk exposure, program effectiveness, control performance, significant issues, emerging risks, and remediation status to senior management, governance committees, and the Board as appropriate.
• May lead, develop, and supervise compliance professionals by setting priorities, assigning work, managing performance, coaching, and supporting talent development and succession planning.
• Lead cross-functional initiatives and working groups and promote consistent interpretation and application of enterprise requirements.
• Maintain current knowledge of regulatory developments, enforcement actions, peer practices, and evolving financial crime risks, and recommend enhancements to the enterprise compliance program.
• Demonstrate Key’s Values and abide by Key’s Code of Conduct.

Benefits

• Eligibility for incentive compensation, which may include production, commission, and/or discretionary incentives.
• The position is eligible for company benefits; specific benefits are not listed in the posting.

What This Job Offers

• Job Type: Full-time
• Career Level: Senior