BSA Investigator

ESSENTIAL FUNCTIONS

• BSA Compliance/Suspicious Activity Reporting:
  • Investigate and analyze system generated BSA/AML alerts in the Bank’s monitoring system for evidence of suspicious activity on a monthly basis.
  • Investigate and analyze high complexity suspicious activity cases, including those escalated by the BSA Specialists to ensure that potentially suspicious transactions are correctly reported within required time frames.
  • Research, investigate, and analyze customer account activity and related behavior for potential money laundering transactions identified by suspicious activity research alerts.
  • Monitor, evaluate and recommend action on multiple intricate cases concerning cash structuring conspiracies, tiered and layered transactions, potential money laundering, potentially illegal activities, and wire transfers going to or from high risk jurisdictions.
  • Compile, record, and maintain appropriate documents and files to promote efficient, consistent, accurate management and regulatory reports.
  • Track and investigate reports of suspicious activity from BSA Specialists, department and front-line staff to ensure SAR filings are reported.
  • Follow and recommend necessary actions to ensure compliance with Bank Secrecy Act/ Anti-Money Laundering (BSA/AML) policies and processes.
  • Recommend closing account(s) and perform necessary follow up procedures to ensure the closure of the account(s).
  • Prepares SAR Investigations on a monthly basis for review by the BSA Committee.
  • Prepares and writes monthly reports for the BSA Committee and the Board of Directors.
  • Prepares SARs filings for timely submission to FinCEN.
  • Responsible for ensuring that SARs are filed for EAC, BEC, MRB, fraud cases, suspicious activity notifications, and escalated cases from the BSA Specialists and responsible for ensuring that BSA Committee recommended actions on accounts have been completed.
  • Evaluates the legal appropriateness of requests for information and prepares responses to law enforcement agencies requesting additional information and documentation resulting from the filing of a SAR.
  • Stay abreast of BSA/AML policy and procedure and FFIEC guidance to ensure compliance with laws and regulations relating to BSA, US Patriot Act, OFAC, Fact ACT, and Elder Justice Act.
  • Investigate and analyze all escalated cases from the BSA Specialists findings in the following areas: EDD, CDD, RDC, ATM, IAT, MSB, MRB, NRA, NGO, CTRs, CTR Exemptions and branch/department reports.
  • Evaluate new account inquiries from branch personnel who are being asked to open accounts for customers in “restricted industries.” If applicable, decline the opening of such account(s).
  • Perform quarterly and annual reviews of customers who are high risk or use high risk products.
  • Create new processes and procedures that are in alignment with the FFIEC guidance and industry standards.
• Fraud Investigation/Elder Abuse Reporting:
  • Respond to and assist departments and front-line staff concerning potential fraud.
  • Assist in mitigating risk, loss mitigation and customer protection.
  • Lead investigations by properly collecting evidence that supports the investigation.
  • Investigate and report fraud cases including account take over, forgeries, counterfeit checks, kiting, embezzlement, wire fraud & deposit fraud and suspicious activity.
  • Review patterns and practices for indicators of identity theft to ensure compliance with the Fact Act.
  • Recommend holds on suspicious and fraudulent transactions or checks; block or close customer accounts and access based on risk and exposure to loss or fraud.
  • Perform research and loss mitigation actions on multiple delivery channels and products to protect bank clients and assets from fraud.
  • Establish and maintain files and records while maintaining client confidentiality and all information security protocol.
  • Investigate unusual trends, provide appropriate case reports and updates to management.
  • Evaluate cases that are moderate to complex in nature to ensure the necessary information and documentation is available. Research case evidence for validity and authenticity.
  • Make decisions that impact processes and clients with financial implications (e.g. force close, pay/no pay, block/hold an account and transaction or access based on analysis of research conducted).
  • Supports BSA Officer with cases that have significant financial loss exposure.
  • Monitor and review fraud cases to ensure proper escalation for SAR filings.
  • Use Anti-Fraud software to detect and identify potential fraud
  • Investigate and analyze various types of system generated alerts for evidence of fraud in our monitoring system.
  • Stay up-to-date with industry best practices and fraud trends and make recommendations to management in order to optimize and refine Bank controls used to detect fraudulent activity.
  • Detect, respond to and report Elder Abuse and Dependent Adult Abuse bank wide.
  • Responsible for filing Elder Abuse reports with the appropriate authorities within the required reporting deadline.
  • Document case investigations according to policy and procedure
• Enhanced Due Diligence

• • Researches, investigates, and analyzes complex higher risk customer account activity and related behavior for potential Money Laundering transactions, terrorist financing, identity theft, financial abuse, fraud, and other criminal activity identified by suspicious activity research.
  • Evaluate, high risk customers, performing enhanced due diligence and suspicious activities monitoring on a quarterly basis.
  • Utilize specialized software, to identify customers requiring enhanced customer due diligence (EDD) that is appropriate for the level of risk being exhibited by high risk customers.
  • Process and evaluate Enhanced Due Diligence on all customers using high risk products offered by the Bank.
  • Identify and research all internal banking relationships for high risk customers and analyze transactions to identify suspicious activity. Work with various departments to document the flow of money between customer accounts.
  • Recommend and file Suspicious Activity Reports and recommend termination of customer banking relationships due to level of risk identified.
  • Maintain records of enhanced due diligence reviews as required by the BSA/AML policy and procedures.
• Office of Foreign Assets Control Compliance
  • Perform research and clear potential OFAC hits.
  • Perform enhanced due diligence for complex sanctions to eliminate and or identify positive matches as required by OFAC Policy.
  • Provide support to the BSA Specialists for potential exact matches with complex sanctions.
  • Provide guidance to branch and department personnel in researching and clearing potential OFAC hits.
  • Perform enhanced due diligence for complex sanctions to eliminate and or identify positive matches.
  • Research and clear all identified potential OFAC matches for wire transfers, IATs, branch and departments on a daily basis.
  • Review and evaluate Office of Foreign Asset Control (OFAC) sanctions using the SDN list.
  • Report exact matches to the BSA Officer to ensure timely reporting to OFAC.
  • Responsible for maintaining the documentation related to close matches that required additional due diligence.
• Red Flags Compliance
  • Perform Identity Theft reviews to ensure appropriate detection, notification and filings are performed in accordance with the Fact Act.
  • Cross screen fraud cases for Identity Theft to ensure compliance.
  • Maintain Identity Theft Program including detection, reporting and recordkeeping requirements.
• 314(a) Searches
  • Responsible for obtaining and upload the 314(a) list provided by FinCEN on a bi-weekly basis or as requested by FinCEN.
  • Conduct required 314(a) database searches and document reviews of potential matches.
  • Report matches to FinCEN within the required reporting timeframe.
  • Maintain the appropriate documentation for 314(a) matches per policy & procedure.
• Examinations & Audits
  • Support BSA Officer with third party Audits and Examinations
  • Coordinate with the BSA officer and BSA department staff to prepare for the impending examinations and audits.
  • Compile requested items, correspond with BSA Specialists and other departments to gather items
  • Monitor & track daily, monthly, semimonthly, quarterly and annual BSA processes ensuring completion for a successful audits and examinations.
  • Respond to Audit / Examination findings and make recommendations to the BSA Officer of any enhancements to processes and procedures.
• Security Support/Law Enforcement Liaison
  • Responsible for maintaining and monitoring the video surveillance systems
  • Member of the robbery response team.
  • Other security related duties as assigned.
  • Establish and preserve relationships with local, state, and federal government agencies to assist investigations.
  • Coordinate with Law Enforcement and prosecutors.
  • Evaluate the legal appropriateness of requests for information and prepare responses to law enforcement agencies.
  • Evaluate the legal appropriateness and prepares responses to law enforcement agencies who request additional information and documentation, resulting from the filing of a Suspicious Activity Report. Document and maintain the requests per the BSA/AML policy and procedures.
• Non-Essential Functions
  • Crossed-trained to provide backup for and act in place of the BSA Officer as needed.
  • Answer more complex, escalated, questions and resolve issues from the branches and departments in conducting alternate Customer Identification Procedures (CIP) for new customers.
  • Perform special projects, research and analysis as requested by the BSA Officer.

MINIMUM QUALIFICATIONS

Education and Experience:

A combination of education and experience equivalent to an associate's degree in business or related field; or a combination of equivalent education and experience and 5 years of experience in bank operations including a minimum of two years’ experience in fraud and BSA/AML compliance, investigations or analysis.

Knowledge, Skills and Abilities:

• Thorough knowledge of current money laundering techniques, terrorist financing, financial abuse, and methods utilized to detect and examine such crimes.
• Detailed understanding of regulatory concepts including, but not limited to, the Bank Secrecy Act, Office of Foreign Assets Control sanctions, and the USA PATRIOT Act.
• Thorough knowledge of how the criminal justice system operates at the Federal and State levels including how to utilize the system to meet the Bank’s goals with regard to security and regulatory requirements.
• An independent decision maker, able to make time-sensitive assessments and to discuss complex regulatory issues with management.
• Ability to effectively interface with business counterparts to obtain information related to client's transaction activity.
• Ability to effectively interact with law enforcement, regulators and other external third parties on behalf of the bank.
• Ability to lead an investigation; including knowledge of how to formulate and execute an investigation.
• Ability to multi-task and work in a fast-paced, deadline-oriented environment.
• Strong leadership skills; willingness to tackle new and difficult challenges.
• Exceptional analytical and research skills.
• Excellent verbal and written communication skills.
• Proficient in MS Office (Outlook/Word/Excel/Access/PowerPoint).
• Skills operating BSA/AML software and compliance monitoring systems, transaction and wire transfer systems.
• Ability to use discretion and work on very confidential matters.
• Ability to work independently with minimum supervision in a detailed and deadline-oriented environment
• Working knowledge of multiple channel fraud issues, detection and mitigation strategies
• Proficiency in Microsoft suite: advanced Excel (Pivot tables, lookup and macro functions)
• Ability to communicate very well in writing and in person.
• Excellent judgment, the ability to take direction and work independently with minimal supervision and as a team player.
• Ability to work in a fast-paced and dynamic environment with a drive to deliver outstanding results.
• Must possess the ability to make logical interpretation of account activity.

Certification:

• Certified Anti-Money Laundering Specialist certification preferred
• Association of Certified Fraud Examiners or Certified Financial Crimes Investigator preferred

Physical Requirements:

• Ability to stand, bend, stoop, sit, walk, twist and turn.
• Ability to lift up to 25 pounds occasionally.
• Ability to use a computer keyboard and calculator.
• Work environment is indoors, majority of the time is spent sitting at a desk.

Compensation:

The hiring range for this position is $30.70 to $42.21 per hour.  The compensation offered will fall within this range, commensurate with the candidate’s applicable experience, education, and skills.