The Head of Financial Crimes and Fraud leads the bank's comprehensive Financial Crimes Risk Management program, including oversight of the Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) function, second-line fraud prevention, and Quality Assurance (QA).
Reporting directly to the Chief Risk Officer, this high-impact leadership role requires a balance of strategic oversight, regulatory expertise, and cross-functional collaboration ensuring the bank complies with all applicable laws and leading a high-performing team.
While the BSA/AML Officer reports to this position administratively, the BSA/AML Officer retains the authority, independence, and direct access to the Board of Directors, CEO, and Chief Risk Officer required by federal regulations to effectively discharge their BSA/AML compliance responsibilities.
This position ensures the Bank maintains a coordinated, integrated and effective risk management framework and meets all regulatory obligations related to fraud prevention and financial crimes compliance
MAJOR DUTIES AND RESPONSIBILITIESSecond Line Leadership & Risk Oversight- Lead and manage three second line functions providing independent oversight and challenge to first line fraud prevention and financial crimes controls
- Develop and execute comprehensive risk-based strategies for fraud oversight and financial crimes compliance aligned with the bank's risk appetite and regulatory requirements
- Assess the design and operating effectiveness of first line controls across all business lines, channels, and product offerings
- Challenge first line risk-taking activities and escalate concerns regarding control deficiencies, emerging risks, or risk appetite breaches
- Establish and monitor key performance and risk indicators, metrics, and reporting frameworks to provide enterprise-wide visibility into fraud and financial crimes risks
BSA/AML Program Oversight & Management- Directly manage the designated BSA/AML Officer administratively and provide strategic direction, resources, and support for the bank's BSA/AML compliance program
- Ensure the BSA/AML Officer maintains the authority, independence, and resources required by federal regulations to effectively discharge their responsibilities
- Provide the BSA/AML Officer with unfettered direct access to the Chief Risk Officer, CEO, and Board of Directors/Board committees without requiring escalation through this role
- Protect the BSA/AML Officer's independence to report regulatory concerns, file Suspicious Activity Reports, and escalate issues without interference
- Ensure the BSA/AML program maintains effective controls for customer due diligence, suspicious activity monitoring and reporting, currency transaction reporting, and OFAC sanctions screening
- Oversee the development and annual refresh of the Bank's BSA/AML risk assessment
- Provide senior-level review and strategic guidance on complex or escalated Suspicious Activity Reports while respecting the BSA/AML Officer's ultimate filing authority
- Ensure the BSA/AML program adapts to evolving regulatory expectations, emerging typologies, and changes in the bank's risk profile
- Manage relationships with transaction monitoring system vendors and oversee system optimization and tuning
Fraud Risk Management- Oversee the second line fraud risk management function, providing independent assessment of fraud prevention, detection, and response capabilities across the enterprise
- Evaluate the effectiveness of fraud controls spanning wire, ACH, card, check, digital banking, and emerging payment channels
- Monitor fraud loss trends, velocity, and patterns;challenge first line on control enhancements and risk mitigation strategies
- Assess fraud risk in new products, services, channels, and partnerships before implementation
- Oversee the Bank's fraud risk appetite framework and escalate breaches or concerning trends
Quality Assurance Function- Lead the independent quality assurance function that performs risk-based quality assurance of both BSA/AML and fraud functions
- Develop annual risk-based QA testing plans covering transaction monitoring alert/case disposition, SARs, CTRs, fraud case management
- Ensure QA findings are appropriately documented, rated, and tracked through remediation
- Validate that corrective actions address root causes and prevent recurrence
- Ensure QA activities support, rather than impede, the BSA/AML Officer's independence and authority
Regulatory Compliance & Examinations- Maintain current knowledge of evolving BSA/AML regulations, fraud-related guidance, and regulatory expectations from FinCEN, OCC, FDIC, Federal Reserve, and other applicable agencies
- Serve as senior liaison with regulators during examinations related to fraud and financial crimes, coordinating responses and managing examination logistics in partnership with the BSA/AML Officer
- Oversee timely and accurate regulatory reporting and filings through the BSA/AML Officer
Governance & Risk Reporting- Chair or participate in governance committees related to fraud risk and financial crimes
- Provide regular risk reporting to the Chief Risk Officer, executive leadership, and Board Risk Committee on fraud and financial crimes exposure, trends, and program effectiveness
- Facilitate the BSA/AML Officer's direct reporting to the Board of Directors (or designated Board committee) at least annually, and more frequently as circumstances require
- Manage issue remediation processes, ensuring timely closure of audit findings, regulatory issues, and internal control deficiencies
- Develop and maintain policies, procedures, and standards for fraud and financial crimes risk management, ensuring BSA/AML policies reflect the Officer's authority and independence
Team Leadership & Development- Build, lead, and develop high-performing second line teams with deep technical expertise in fraud risk, BSA/AML compliance, and quality assurance
- Any other tasks as needed commensurate with the role/position