Deputy Chief Compliance Officer / Deputy BSA Officer

This is a fully remote position, open to applicants in California.

📋 Description

• Assist the CCO/BSA Officer in developing and upholding the trust bank’s Compliance Management System, which includes policies and procedures, training, monitoring, testing, issue management, and reporting to the Board.

• Aid in the creation, maintenance, and implementation of BSA/AML policies, procedures, and internal controls in alignment with 31 CFR 1020.210.

• Support processes related to customer identification, customer due diligence, enhanced due diligence, beneficial ownership, and continuous customer risk rating.

• Manage daily compliance operations concerning transaction monitoring, alert reviews, case escalations, SAR investigation support, and FinCEN reporting workflows.

• Assist with OFAC sanctions screening, sanctions escalation, compliance with the Travel Rule, and screening processes for digital asset wallets.

• Contribute to the implementation and optimization of blockchain analytics tools for transaction monitoring, wallet screening, typology development, and sanctions risk detection.

• Develop and sustain AML typologies, red flags, and escalation procedures specifically for digital asset custody and fiduciary activities.

• Coordinate compliance monitoring and testing efforts, including tracking findings, remediation plans, root-cause analyses, and evidence of closure.

• Support the annual independent BSA/AML audit and compliance testing, ensuring findings are reported, tracked, and addressed.

• Assist in preparing for OCC examinations, including document production, management responses, and remediation of supervisory findings.

• Facilitate regulatory change management for relevant banking, fiduciary, BSA/AML, OFAC, Travel Rule, and emerging digital asset requirements.

• Prepare compliance reports for the CCO, President & CEO, Board Audit & Risk Committee, and other governance forums.

• Collaborate closely with the CCO, Risk Lead, COO, CFO, CISO, Legal, and appropriate first-line teams while ensuring independence from revenue-generating business activities.

⛳️ Requirements

• A minimum of 7 years of experience in compliance, BSA/AML, financial crimes, or regulatory compliance within a federally supervised financial institution or similarly regulated financial services firm.

• Extensive knowledge of BSA/AML program requirements, including Customer Identification Program (CIP), Customer Due Diligence (CDD)/Enhanced Due Diligence (EDD), SAR processes, transaction monitoring, OFAC sanctions screening, and regulatory reporting.

• Experience in supporting compliance programs subject to examination by the OCC, Federal Reserve, FDIC, FinCEN, or state banking regulators.

• Familiarity with compliance management systems, compliance testing, issue management, regulatory change management, and reporting to the Board.

• Experience with AML risks related to digital assets, blockchain analytics, virtual currency typologies, wallet screening, or compliance with the Travel Rule.

• Proven ability to work independently, appropriately escalate issues, and maintain the compliance function's independence from business line objectives.

• Strong written and verbal communication skills, with the capability to prepare clear compliance documentation for senior management, auditors, and regulators.

• Must demonstrate a personal history of responsibility, honesty, and integrity, and meet OCC background investigation requirements that assess competence, experience, integrity, and financial capability.

• CAMS certification is highly preferred.

• Previous experience at a trust company, custody bank, digital asset exchange, or digital asset custody provider.

• Experience in building or scaling a BSA/AML or compliance program for a de novo bank, trust company, or newly regulated financial institution.

• Familiarity with OCC or FinCEN examinations, independent BSA/AML audits, or remediation of Matters Requiring Attention (MRAs), Matters Requiring Immediate Attention (MRIAs), consent orders, or similar supervisory findings.

• Knowledge of OCC safety and soundness expectations, 12 CFR Part 9 fiduciary requirements, OCC Bulletin 2023-17, and 12 CFR Part 30.

• Understanding of emerging regulatory frameworks related to digital assets, including stablecoin, qualified custodians, and digital asset custody requirements.

🏝️ Benefits

• Option for remote work.

• Medical insurance coverage.

• Flexible time off policy.

• Retirement savings plans available.

• Modern family planning options.

• Reasonable accommodations provided throughout the recruitment process.