JOB TITLE/ JOB CODE NAME
JOB FAMILY LEVEL
COMPLIANCE Assistant Vice President
REPORT TO (JOB TITLE)
Head of Compliance, SVP
1. JOB PURPOSE
The Bank Secrecy Act Officer is responsible for developing, implementing and
administering the day to day of all aspects of the AML/BSA Compliance
Program. This position performs various quality control reviews and monitoring
in the area of Bank Secrecy Act, USA Patriot Act, Anti-Money Laundering,
OFAC and Customer Identification Program compliance using industry standard
and regulatory guidance sampling methods to ensure the Bank's compliance efforts
are maintained on a daily basis. Advises the Bank's Chief Compliance Officer,
Senior Management and Bank personnel of emerging compliance issues and
consults and guides the Bank in the establishment of controls to mitigate risks.
Assists the Chief Compliance Officer in ensuring department activities run
smoothly and efficiently by providing leadership, training and supervision within
the department. The position of Bank Secrecy Act Officer performs direct
supervisory duties of assigned department staff, coordinates staff for coverage in
assigned areas of the department, and is required to be fully knowledgeable and
skilled in all areas of the department.
2. REPORTING RELATIONSHIPS
(a) Position in Department/Branch
AML/ BSA Officer
(b) Relationship with other Departments
Heavy interdependencies with operations department (both bank and broker
dealer), as well as Products area.
Heavy interdependencies with peer Sales Support staff & Operations area.
3. PRINCIPAL ACCOUNTABILITIES
Identify and measure the BSA/AML and OFAC risks associated with products
and services offered by the Bank and advise management on the development
of policy, procedures, systems, controls and training to address those risks.
Maintain the BSA/AML and OFAC Compliance Programs for TCF National
Bank, encompassing all business lines and legal entities for which Corporate
BSA is responsible for day-to-day operations. Submit Program for BOD
Update the written BSA/AML and OFAC risk assessments (RAs) at least
every 12-18 months for approval by the Bank BOD. Ensure RAs are
communicated with all business lines across the bank, management and
Work with the Bank’s Enterprise Risk Manager to develop and maintain
benchmarks for dashboard reporting. Provide periodic updates for ERM
reporting to the executive management, Board of Directors and the TCFFC
Prepare reports concerning BSA-related risk and activities to the Bank Board
of Directors and TCFFC Audit Committee as well as other reports to senior
management, including but not limited to the BSA Administrative Committee.
Maintain Corporate BSA Department Procedure Manual implementing the
BSA/AML and OFAC Programs. Assist BSA Officer and managers with
ensuring departmental procedures are current and in compliance with
regulatory/agency requirements and bank policy.
Coordinate all internal and external examinations of department activities,
including independent testing and external examinations. Assist with the
preparation of audit and examination responses, including monitoring the
completion of management commitments/corrective action.
Assist the Director with the development of department goals and objectives.
Monitor and report progress towards completion of those goals and objectives.
Monitor BSA/AML industry developments and maintains advanced
knowledge of new and amended laws and regulations impacting the Program
and Risk Assessment.
4. BUSINESS IMPACT AND SCOPE
Effectiveness of accuracy impacts quality of information in customer’s files
and contribute to Relationship Manager’s achievement of compliance
Effectiveness impacts customer satisfaction and overall impression customers
have of the Bank.
5. EXTERNAL CONTACTS
Outside vendors, auditors.
6. KNOWLEDGE AND EXPERIENCE REQUIRED
•Bachelor’s degree or equivalent work experience.
•Certified Anti-Money Laundering Specialist (CAMS) designation.
•Four-year degree in business, management or other related field.
•Four or more years experience as a Consumer Compliance Officer, BSA Officer or
Risk Officer in a mid-size or large bank.
•Fully knowledgeable of the BSA and all related regulations.
•Solid understanding of the bank’s products, services, customers and entities, and
geographic locations, and the potential money laundering and terrorist financing risks
associated with those activities.
•Excellent written and verbal communication skills.
•Ability to build relationships using teamwork, problem identification and problem
•Willingness and assertiveness to express expertise and authority to meet the
requirements for the position.
•Excellent project and time management skills.
•Proficient in the use of Microsoft suite products.
Job Description agreed
Immediate Supervisor_______________________(signature) Name _____________
Job Title___________________________ Date_______________