Business Line Liaison III

The Business Line Liaison services the bank’s business segments by providing subject matter expertise to facilitate implementation, maintenance and ensure regulatory compliance with anti-money laundering programs implemented by the bank in order to mitigate regulatory and reputational risk and reduce exposure to civil and criminal liability as they apply to the bank’s products, services, processes and systems regarding BSA/AML and OFAC regulations.

The Business Line Liaison supports and coordinates efforts with all units of the bank (for example, internal and external audit, FIU, alerts, private banking etc.) as required to ensure compliance to all regulatory matters as needed.

Responsibilities:

• Monitor and Ensure timeliness and quality of RFI responses to BSA Units
• Monitor timeliness and quality of KYC/KYA update requests (periodic or requested) as required by policy that originate from various BSA units and review processes, liaisons, and CDD EDD units and that may be requested for any account under review/investigation, or after visiting a customer or obtaining information that merit an update.
• Monitor timeliness and quality of customer visitation recordkeeping and receipt of financial statements as required for certain high-risk accounts. Depending on the business unit, this could include visiting the customer or coordinating the visitation process performed by external resources.
• Monitor timeliness and quality of any KYC/KYA or CDD/EDD exceptions noted by the CDD/EDD Unit.
• Monitor timeliness of account closures. For those cases in which the business line is requesting consideration for the account to remain open, the liaison is to review the quality of information and documentation compiled by the business officer and forward the case to BSA Management in a timely manner such that a decision may be made prior to the account closure due date. Coordinate an open house meeting prior to the closure due date if the complexity warrants such.
• Coordinate with the business officer the review of account documentation for new customers classified as high risk under the BSA program prior to submission to CDD/EDD Unit and for approval of the account and potential follow up afterwards.
• Review documentation compiled by the business officer for presentation of PEPs to EC for approval.
• Complex structure reviews to ensure ultimate beneficial ownership is known and verified through documentary means; review includes adverse media searches, Lexis Nexis report review, verification of existence of entity through formation documents and Good Standing certificates, and documentary verification of ownership.
• Provide assistance to officers and credit services on BSA matters regarding potential or existing loan customers.
• Provide assistance to the business officers in reviewing Adverse Media to determine necessity for escalation to other BSA units.
• Monitor timeliness and quality of responses to inquiries on potential OFAC matches from the business officer.
• Identify BSA training needs in the business line and report to line of business and BSA Management. Collaborate with BSA Management to develop the scope and learning objectives for compliance training for the business line. Conduct BSA training for employees of the business line in support of the BSA Training Program as needed.
• Provide BSA subject matter expertise to business unit staff regarding new and/or changes to products, services, processes, and systems. Communicate with BSA Management on these matters.
• Identify potential BSA-related opportunities for improvements within business units and communicate with BSA Compliance Management
• Provide recommendations to Compliance, Business Line management and DPAC Manager on changes in compliance workflow processes to improve efficiencies and mitigate compliance risk.
• Ensure coordination with liaison unit to ensure uninterrupted departmental coverage during absence, vacation, etc.
• Serve as mentor for entry level Liaisons.
• Ensure preventive measures are carried out to fully comply with current rules, regulations and internal policies relating to risks pertaining to BSA, USA Patriot Act, OFAC and other AML related issues.
• Identify, evaluate, monitor and make any recommendation deemed necessary to the supervisor in order to assess, reduce, eliminate or control any current or prospective risks to earnings or capital arising from violations of, or nonconformance with, laws, rules regulations, prescribed practices, internal policies and procedures or ethical standards.
• Responsible for the preparation of reports and responses to internal and external audits related to Compliance.
• Maintain current knowledge of Compliance law, Bank Secrecy Act, US Patriot Act and other laws related to Compliance and how they affect the financial institution.
• Responsible for the review of new customer account documentation classified as High Risk under the BSA program.
• Ensure compliance rating is maintained as satisfactory and address corrective actions when needed in order to ensure that the business units maintain acceptable ratings.
• When applicable, conduct enhanced due diligence on adverse findings yielded from public records or AMS searches and take appropriate action.
• Assist in the account opening process, organization of documents, implementation of new strategies approved by the units and Compliance, shortening the time for new account openings complying with the bank’s policies and US regulations.
• Identify and report to management any lack of diligence and/or responses from officers and/or managers to Compliance BSA/AML matters, BSA inquiries and/or any other Compliance matters.
• Support in maintaining up to date account file documentation.
• Stay abreast of changes in the regulatory environment that affect the business lines.
• Identify, evaluate, monitor and make any recommendation deemed necessary to the supervisor in order to assess, reduce, eliminate or control any current or prospective risks to earnings or capital arising from violations of, or nonconformance with, laws, rules regulations, prescribed practices, internal policies and procedures or ethical standards.
• To identify, evaluate, monitor and make any recommendation deemed necessary regarding Risk Management; the existence of a Compliance Liaison for business segments allow the business units to become more proactive and take preventative and timely measures to fully comply with the current rules and regulations regarding risks pertaining to BSA, US Patriot Act, AML issues, and various others.
• Participate in team meetings.
• Other duties assigned by Supervisor.

Minimum Education and/or Certifications Requirements:

Bachelor’s degree in finance, Business Administration, Economics, ACAMs or CRCM certification preferred.

Minimum Work Experience Requirements:

5 to 7 years as an officer in a BSA/Compliance or Internal Control position in the banking industry, preferably in anti-money laundering compliance in an international banking environment. Supervisory experience preferred. Bilingual English/Spanish preferred

Technical and/or Other Essential Knowledge:

Strong knowledge of the Bank Secrecy Act and OFAC regulations and compliance controls. Knowledge of banking financial principles, products and process involved in banking activities.