Fintech BSA Officer

First Federal Bank of Kansas City•Leawood, KS

2d•Remote

About The Position

This position is responsible for the First Federal Bank of Kansas City's (bank or FFBKC) Bank Secrecy Act, anti-money laundering, sanctions, and Office of Foreign Assets Control (BSA/AML/OFAC) program for its Banking-as-a-Service (BaaS) / financial technology company (fintech) business line. The Fintech Bank Secrecy Act Officer (Fintech BSA Officer) will ensure the bank's compliance with all applicable laws and regulations related to anti-money laundering, sanctions, and other financial crimes. Working proactively and collaboratively with bank employees and leadership, the Fintech BSA Officer will be the subject matter expert for all applicable laws, regulations, regulatory guidance and examination manuals concerning BSA/AML/OFAC and ensure that effective processes, controls, documents, training, risk assessments, reports and procedures have been developed, completed, implemented, and maintained.

Requirements

Eight (8) or more years of experience in BSA/AML/OFAC in financial services.

Nice To Haves

Experience in data analytics, fintech oversight and SardineAI strongly preferred.
Applicable industry certification preferred (such as Certified Regulatory Compliance Manager (CRCM) or Certified Anti-Money Laundering Specialist (ACAMS)).

Responsibilities

Administer and maintain the BSA/AML/OFAC compliance program applicable to the BaaS / Fintech vertical, ensuring compliance with all applicable laws, regulations, regulatory guidance, examination manuals, and third-party obligations.
Develop, maintain, and update a written BSA Program for the BaaS / Fintech business line for review by the Board of Directors at least annually.
Provide timely and accurate reporting to the Chief Risk Officer, the Enterprise Risk Management Committee, Fintech Committee, the Audit and Risk Committee, and the Board of Directors regarding BSA/AML/OFAC activities and risks related to fintech operations.
Conduct comprehensive BSA/AML/OFAC risk assessments of fintech partners prior to onboarding and on an ongoing basis.
Perform an annual risk assessment of the BaaS / Fintech BSA/AML/OFAC program and update assessments as changes occur.
Assign customer risk ratings and oversee customer due diligence (CDD) and enhanced due diligence (EDD) activities based on identified risks.
Evaluate alert activity, case investigations, and account monitoring results and make account restriction or closure recommendations as appropriate.
Ensure that all BSA/AML/OFAC policies, procedures, forms, disclosures, agreements, notices, and related documentation applicable to the fintech business line are current and compliant.
Develop and maintain procedures for know your customer' (KYC), 'know your business (KYB), Customer Identification Program (CIP), transaction monitoring, sanctions screening, record retention, and information sharing specific to fintech activities.
Establish and monitor key performance indicators (KPIs) and key risk indicators (KRIs) for the fintech BSA/AML/OFAC program.
Ensure that all Bank employees and fintech partners receive appropriate BSA/AML/OFAC training commensurate with their roles and responsibilities.
Positively promote a strong culture of compliance with the BaaS / Fintech business line through education, communication, and ongoing program enhancements.
Administer and oversee software systems use for KYC/KYB, CIP, transaction monitoring, and sanctions screening for fintech activities.
Evaluate system effectiveness and implement enhancements to improve efficiency, accuracy, and reporting capabilities.
Serve as primary point of contact for regulatory examinations, audits, and reviews related to the BaaS / Fintech BSA/AML/OFAC program.
Maintain knowledge of regulatory priorities, enforcement actions, and changes to applicable laws and regulations and communicate relevant updates to management.
Review subpoenas and law enforcement requests related to fintech accounts and activity.
Act as lead liaison for 314(b) information sharing requests and ensure registration is completed annually with FinCEN for the BaaS / Fintech vertical.
Oversee compliance with the Unlawful Internet Gambling Enforcement Act (UIGEA) as it applies to fintech activities.
Implement and maintain an effective Identity Theft (Red Flags) Prevention Program in accordance with the Federal Financial Institution Examination Council (FFIEC) and Federal Trade Commission (FTC) issued rules and guidelines implementing section 114 of the Fair and Accurate Credit Transactions Act of 2003 (FACT Act) and final rules implementing section 315 of the FACT Act for the BaaS / Fintech vertical.
Ensure BSA/AML/OFAC and identity theft risks are addressed in business continuity and disaster recovery planning.
Ensure appropriate controls are in place to address insider abuse and employment-related compliance requirements.
Other activities and functions as deemed necessary or appropriate by the Chief Risk Officer.
Complies with all applicable banking laws and regulations, including, but not limited to, the Bank Secrecy Act, USA PATRIOT Act, and related anti-money laundering laws and regulations; and federal consumer protection legislation and regulations.