Senior Compliance Officer – Enterprise FinCEN Programs Governance SME

KeyBank•Brooklyn, OH

5d•$96,000 - $181,000•Hybrid

About The Position

The Senior Compliance Officer serves as Financial Crimes Risk Management’s (FCRM) enterprise subject matter expert and senior second-line compliance authority for technical compliance with, and the spirit of, FinCEN Programs. These include Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs, including Purchase and Sale of Certain Monetary Instruments Recordkeeping or the Monetary Instrument Log [MIL]), Reports of Foreign Bank and Financial Accounts (FBARs), Special Measures under Section 311 of the USA PATRIOT Act, and Information Sharing under Sections 314(a) and 314(b) of the USA PATRIOT Act. 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 officer 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. The position serves as the senior compliance escalation point for interpretation and application of enterprise requirements in its subject matter areas. It provides independent credible challenge, documents material concerns and recommendations, and recommends approval, conditional approval, escalation, remediation, restriction, or decline when compliance requirements or risk appetite are not met. The officer is accountable for the quality, consistency, and timeliness of second-line guidance, influence, and oversight within the assigned domain. The role is based at the listed Brooklyn, Ohio location, with preferred locations in Cleveland or Buffalo and a hybrid in-office schedule of three or more days. The position is eligible for a base salary of $96,000 to $181,000 annually and incentive compensation, which may include production, commission, and/or discretionary incentives. Key describes its workspace approach as prioritizing in-office presence while providing flexible options when roles can be performed effectively in a mobile environment.

Requirements

Bachelor’s degree or an equivalent combination of education and relevant experience.
Extensive experience in BSA/AML, financial crimes compliance, regulatory compliance, risk management, Legal, Internal Audit, or a related discipline within a financial institution or regulatory environment, specifically involving SAR, CTR/MIL, FBAR, Special Measures, and Information Sharing operations.
Deep knowledge of SAR, CTR/MIL, FBAR, Special Measures, Information Sharing, and risk-based compliance program regulations and regulatory 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, including related technology, 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.
Ability to meet the physical demands of a general office setting, including prolonged sitting, communicating face to face or by phone, frequent PC/laptop use, and occasional lifting, pushing, or pulling of computer or backpack bags up to 10 pounds.

Nice To Haves

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.
Experience with large or complex financial institutions, multiple lines of business, enterprise transformation, regulatory remediation, or direct regulatory examination engagement or oversight.
Knowledge of data governance, model risk management, technology controls, automation, and systems supporting customer onboarding and lifecycle management.

Responsibilities

Serve as the enterprise subject matter expert for SARs, CTRs/MIL, FBARs, Special Measures, Information Sharing, and related regulatory requirements and industry practices.
Execute risk oversight activities in accordance with the FCRM governance framework, standards, and requirements.
Oversee technology evolution and transformation, data governance, data lineage and flows, data quality, data dependencies and access, data platforms, record retention, system functionality, automated decisioning, rules, models, and other technology changes affecting FinCEN Programs.
Learn and identify end-to-end processes at KeyBank for the assigned FinCEN Programs, including technology inputs and manual processes that could affect outputs, to support compliance.
Provide second-line oversight and credible challenge of enterprise processes, procedures, controls, systems, tools, data, and operational practices supporting FinCEN Programs.
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 and provide authoritative review and approval of enterprise policies and standards for FinCEN Programs, and oversee governance of supporting first-line procedures and job aids.
Evaluate control design and whether control execution is effective, consistent, evidenced, and sustainable across the enterprise.
Identify gaps, emerging risks, inconsistent practices, control weaknesses, and potential regulatory exposure; communicate risks 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 FinCEN Programs.
Define and monitor risk appetite, risk tolerance, key risk indicators, key performance indicators, control metrics, quality results, exceptions, backlogs, aging, and other program-health information.
Review and challenge business process risk identification, new or modified products and services, customer journeys, delivery channels, acquisitions, integrations, third-party arrangements, and material changes that may affect FinCEN obligations.
Provide senior compliance guidance and influence on complex, high-risk, novel, or escalated customer matters.
Partner with Legal, BSA/AML leadership, FCRM teams, 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 provide credible challenge to 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 preparation of narratives, evidence, issue responses, and senior management or governance committee presentations.
Oversee identification and remediation of issues and findings, severity assessment, root-cause analysis, corrective-action design, validation readiness, risk acceptance, and sustainable closure.
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 concise 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.
Lead cross-functional initiatives and working groups, mentor compliance professionals, and promote consistent interpretation and application of enterprise requirements without direct supervisory responsibility.
Maintain current knowledge of regulatory developments, enforcement actions, peer practices, and evolving financial crime risks, and recommend enhancements to the enterprise compliance program.
Act as the senior compliance escalation point for interpretation and application of enterprise SAR, CTR/MIL, FBAR, Special Measures, and Information Sharing requirements.
Provide independent credible challenge, document material concerns and required actions, and make risk-based recommendations.
Recommend approval, conditional approval, escalation, remediation, restriction, or decline when compliance requirements or risk appetite are not met; maintain required documentation under FCRM governance standards.
Escalate material regulatory risk, control breakdowns, overdue remediation, or unresolved disagreements through established governance channels.