Deputy BSA and Deputy OFAC Officer - Hybrid/Remote

First American Bank was founded in Chicago, and over the years has expanded throughout Wisconsin and Florida. As the largest privately held bank in Illinois, we now have over 60 locations and assets of $5+ billion. We are a community bank at heart with international expertise, traditional values, and a forward-looking philosophy. Our employees have the experience and vision to meet the needs of savers, borrowers, and businesses in the 21st century. First American Bank can offer employees a level of visibility, career growth, and stability that is difficult to find in many larger corporations.

The Deputy BSA and Deputy OFAC Officer serves as an escalation point for complex regulatory matters, providing expert guidance and strategic oversight. This individual drives the administration of the Bank's Sanctions Compliance Program (SCP), ensuring enterprise-wide policies and procedures align with the Office of Foreign Assets Control (OFAC) regulations. Additionally, the Deputy leads the Sanctions-Watchlists team, optimizing operational effectiveness, mitigating risk, and strengthening compliance across the institution. The Deputy officially represents the BSA Officer and assumes the role in their absence or unavailability, ensuring continuity in oversight and compliance responsibilities for the department.

DUTIES & RESPONSIBILITES

Regulatory Compliance/Governance/Internal Controls

Maintain an understanding of relevant laws, regulations, guidelines, and advisories issued by OFAC, FinCEN (Financial Crimes Enforcement Network), BIS, and other regulatory bodies pertaining to economic sanctions, AML, and CTF.
• Work with BSA Officer to assure relevant policies, procedures, and practices align with regulatory framework requirements.
• Conduct periodic reviews of lines of business and legal entities' policies and procedures.
• Work with BSA Officer and/or LOB representative to implement updates to policies and procedures in response to regulatory updates or changes in the organization's risk profile.
• Responsible for remediation of all outstanding audit and regulatory issues assigned
• Serves as subject matter expert for BSA, OFAC, and watchlists tasks and questions.
• Make informed decisions regarding sanctions-related issues, including the blocking of assets and the imposition of sanctions on individuals or entities.
• Evaluate suspicious activity reports with careful analysis, making informed determinations that may involve authorizing SAR filings when necessary.
• Ensure timely and thorough review, triage, and investigation of alerts generated: ensures all dispositions of watchlists alerts occur timely; and escalate to the EDD Investigations group for additional review and determination of potential suspicious activity.
• Conduct prompt and comprehensive assessments of sanctions and watchlist alerts, ensuring timely dispositions. Escalate cases to the EDD Investigations group when further review is necessary to determine potential suspicious activity.
• Ensure and validate timely disposition, and detailed, consistent documentation of Sanctions and Watchlists alerts per procedures, as directed by BSA Officer.
• Works directly with Bank Operations, Compliance, Legal, and other relevant parties to ensure blocked and/or restricted assets are properly documented, titled, and coded within internal systems. Periodically reconcile blocked accounts.
• May create and/or file periodic reports with BSA or other government entities.
• Participate in internal committees or working groups focused on risk management, compliance, or regulatory affairs.

Management

• Oversee a team of BSA Specialist within the BSA Compliance Department. Directly manage the daily activities of employees within the department, coordinating and prioritizing requisite duties and daily assignments while appraising employee productivity and performance. Compose and deliver performance evaluations.
• Responsible for employee hiring, training, staff development, scheduling, and direct assistance with the coverage of daily workloads when needed. Monitor work standards and adherence to company policies. Proactively deliver feedback to direct reports to promote staff development, and administer corrective action as needed.

Training

• Develop and deliver training to raise awareness and understanding of BSA/sanctions compliance requirements and best practices, as needed.
• Create and provide, directly or indirectly, in coordination with the BSA Officer - Training team, new hire, annual, and additional training if/when necessary, to relevant business lines and applicable non-bank affiliates.
• Promote a culture of compliance throughout the organization by raising awareness of sanctions-related risks and obligations.

Strategic Planning and Decision Making

• Contribute to the development of the department's strategic objectives and initiatives related to BSA-sanctions compliance.
• Provide strategic guidance to senior management on emerging trends, regulatory developments, and potential risks in the BSA-sanctions landscape.
• Identify process improvements and streamlining of Sanctions and Watchlists compliance.
  Risk Assessment and Mitigation.
• Maintain awareness of emerging sanctions risks, assess how they may impact the Bank, and develop and implement risk mitigation strategies to address identified risks effectively and withing the organization's risk tolerance.
• Perform or oversee the performance of an overall BSA and OFAC Sanctions risk assessment to identify potential vulnerabilities related to sanctions compliance.
• Regularly assess the effectiveness of the sanctions compliance program and internal controls and make recommendations for improvements, as needed.
• Establish and maintain effective internal controls to ensure the integrity and accuracy of sanctions screening processes.
• Performs fuzzy logic testing through a documented period testing plan, ensuring systems all calibrated and change management is fully documented and adhered to.
• Works directly with the Systems-Data Governance Manager to identify and catalog all data feeds and systems related to Sanctions and watchlists compliance, creating flowcharts of each system/process.
• Responsible for ensuring all watchlists updates are conducted successfully and in a timely manner.
• Creates metrics to measure the Bank's, and applicable legal entities' compliance with Sanctions and Watchlists requirements, to support improvement of BSA and OFAC Sanctions-Watchlists functions, and to keep the OFAC Officer and other key stakeholders abreast of the state of the Sanctions compliance program.
• May deliver/present results of such metrics to key stakeholders in person or virtually.

Cross-functional Collaboration and Communication

• Collaborate with other departments, including Legal, Risk Management, Systems/Data Governance, Internal Audit, and Business Units to address sanctions-related matters and ensure a coordinated approach to compliance.
• Liaise with law enforcement agencies, government entities, and industry associations on sanctions-related investigations, questions, intelligence sharing, and industry initiatives.
• Draft communications related to BSA updates for communication to lines of business and applicable non-bank affiliates, as necessary.
• Conduct and complete additional assignments/projects as designated by management.

QUALIFICATIONS

• High school diploma or equivalent required. Bachelor's degree in Criminal Justice, Business, or a related field is preferred.
• Certification as a compliance professional (CGSS, CAFP, CAMS) is required.
• Minimum five years of anti-financial crimes and/or sanction, primarily in BSA and OFAC, experience is required.
• Working knowledge of export risks and controls, sanctions framework requirements, and risk assessments are required.
• A strong understanding of relevant laws, regulations, and industry guidelines concerning economic sanctions, AML, CTF, export controls, and financial crime prevention is essential.
• Ability to research and interpret sanctions regulations. Strong practical knowledge of laws applicable to money laundering including OFAC, USA PATRIOT Act, Department of U.S. Treasury BSA requirements, and SAR reporting is required.
• Knowledge of, and ability to apply, Sanctions / AML rules and regulations to prevent or report Sanctions-related activities and money laundering in the financial services industry.
• Experience with model risk management activities related to BSA model tuning and implementation is highly preferred.
• Previous management experience in financial crimes operational and policy capacities is highly preferred.
• Knowledge of Fuzzy Logic application and testing systems for BSA compliance is preferred.
• Experience selecting, implementing, and managing BSA screening platform(s) and working effectively with vendors is preferred.
• Experience in leading or managing compliance teams, projects, or initiatives, with a demonstrated ability to oversee sanctions compliance activities effectively and drive organizational change is preferred.
• Demonstrated ability to interact with all levels of management and other business lines with tact and diplomacy while achieving stated objectives.
• Demonstrated sound judgment and decisive problem-solving under tight time constraints, ensuring well-founded conclusions. Apply exceptional analytical skills to navigate complex sanctions scenarios with precision, maintaining rigorous attention to detail, and accurate documentation.
• Must be able to work effectively with internal auditors, regulatory bodies, and other entities with oversight functions.
• Must be professional, comfortable speaking with external and internal contacts with a demonstrated ability to tailor the message appropriately to the audience and situation effectively.
• Demonstrated ability to convey thoughts and ideas effectively and succinctly via written formats, including emails, letters, and electronic platforms. Maintain professional standards relating to spelling and grammar.
• Maintain credibility through professional demeanor, appearance, and presence by modeling standards appropriate to our environment and industry.
• Maintain good working relationships with internal partners by exhibiting exemplary interpersonal skills, adopting a constructive, solutions-focused approach.
• Use sound professional judgment to balance the interests of the organization and customer, understanding and using available resources to mitigate risks.
• Proficiency with Microsoft 365 products and applications, including the ability to effectively prepare or review documents, procedures, and reports. Proficiency in Microsoft Excel and Power BI is required.
• Demonstrated ability to learn new systems and applications, as well as the ability to understand, adapt and adjust responsibilities/workflows as a result of system upgrades.
• Occasional travel to other First American Bank locations, Bank functions, and training facilities may be required.
• Flexible work from home options available.
• Typical schedule is Monday through Friday 8:00 a.m. to 5:00 p.m. Additional hours may be required depending upon business need.
• Punctuality is required to maintain First American Bank's customer service standards.