Senior Compliance Officer – Enterprise FinCEN Programs Governance SME

KeyBank • Brooklyn, OH

3d • Hybrid

About The Position

The Senior Compliance Officer serves as Financial Crimes Risk Management’s enterprise subject matter expert and senior second-line compliance authority for technical compliance with, and the intent of, FinCEN Programs. These include Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), 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 ensure that relevant processes, procedures, standards, controls, systems, data, and documentation are appropriately designed, implemented, maintained, and operating effectively. It partners across the first, second, and third lines of defense to identify regulatory risk, assess controls, resolve complex matters, drive sustainable remediation, and promote consistent execution across applicable legal entities, businesses, products, channels, and customer segments.

The position is the senior compliance escalation point for interpreting and applying enterprise requirements in its subject matter domain. It provides independent credible challenge, communicates material concerns and risk-based recommendations, and escalates material risks, control breakdowns, overdue remediation, and unresolved disagreements through established governance channels. The role leads cross-functional initiatives and mentors compliance professionals without direct supervisory responsibility.

The preferred work locations are Cleveland or Buffalo, with a hybrid in-office schedule of three or more days. The role is eligible for an annual base salary of $96,000 to $181,000, with eligibility for incentive compensation. Key’s workspace approach prioritizes in-office presence while offering flexible options where work 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, or Information Sharing operations.
• Deep knowledge of SAR, CTR/MIL, FBAR, Special Measures, Information Sharing, and risk-based compliance program regulations and regulatory expectations.
• 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 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.
• Ability to lead cross-functional initiatives, influence senior stakeholders, and provide credible challenge in a complex, highly regulated environment.

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 practices.
• Execute risk oversight in accordance with the FCRM governance framework, standards, and requirements.
• Provide compliance oversight of technology changes, data governance and lineage, data quality, data access and platforms, record retention, system functionality, automated decisioning, rules, models, and other changes affecting FinCEN Programs.
• Understand end-to-end processes and technology inputs or manual processes affecting FinCEN Program outputs.
• Provide second-line oversight and credible challenge of enterprise processes, procedures, controls, systems, tools, data, and operational practices supporting FinCEN Programs.
• Interpret laws, rules, regulatory guidance, examination expectations, and enforcement themes; assess enterprise impacts and translate requirements into policies, standards, controls, and implementation guidance.
• Own and provide authoritative review and approval of enterprise FinCEN Program policies and standards, and oversee governance of supporting first-line procedures and job aids.
• Evaluate control design and operating effectiveness, including consistency, evidence, and sustainability across the enterprise.
• Identify gaps, emerging risks, inconsistent practices, control weaknesses, and regulatory exposure; communicate risks and require 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.
• Define and monitor risk appetite and tolerance, KRIs, KPIs, control metrics, quality results, exceptions, backlogs, aging, and other program-health information.
• Review and challenge business process risk identification, products and services, customer journeys, channels, acquisitions, integrations, third-party arrangements, and material changes affecting program obligations.
• Provide senior compliance guidance and influence on complex, high-risk, novel, or escalated customer matters.
• Partner with Legal, BSA/AML leadership, FCRM, business compliance, operations, technology, data, model risk, fraud, privacy, third-party risk, Internal Audit, and independent testing teams.
• Oversee, develop, or credibly challenge quality assurance, compliance monitoring, independent testing, internal audit, and regulatory examination activities; assess results and track management responses.
• Provide subject matter leadership for examinations, audits, inquiries, and information requests, including preparation of narratives, evidence, issue responses, and presentations.
• Oversee issue and finding identification, severity assessment, root-cause analysis, corrective-action design, validation readiness, risk acceptance, remediation, and sustainable closure.
• Establish enterprise training requirements and provide or oversee targeted training, communications, implementation materials, and subject matter support.
• 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.
• Lead cross-functional initiatives and working groups, mentor compliance professionals, 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 program enhancements.
• Recommend approval, conditional approval, escalation, remediation, restriction, or decline when requirements or risk appetite are not met.
• Maintain required documentation and escalate material risks, control breakdowns, overdue remediation, and unresolved disagreements through established governance channels.
• Demonstrate Key’s Values and abide by Key’s Code of Conduct.

Benefits

• Eligible for incentive compensation, which may include production, commission, and/or discretionary incentives.
• Flexible work options in circumstances where the role can be performed effectively in a mobile environment.

What This Job Offers

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