The Sr. BSA/AML Investigations Analyst is responsible for performing, monitoring and/or investigation of potential suspicious activity, ensuring accurate, comprehensive and timely submission of all required reports. Apply acquired investigative techniques in the analysis of complex transactional activity that potentially represents criminal activity, money laundering or terrorists financing activities. Submit a wellorganized and thorough investigative narrative that provides a clear, concise and documented summary of the transactional review. Assists BSA management, as requested, in performing various research functions including but not limited to reviewing and preparing month end reports. Provide assistance in performing first level reviews for no-SAR cases. Mentor and work with other less experienced staff in developing additional assets within the team.
Responsible for suspicious activity investigations and reporting. Review and analyze account or customer transactional activity for potential money laundering or terrorist financing. Apply critical thinking skills and experience in providing a thorough and comprehensive narrative justifying the decision to forward to the Investigations Team for further review or if being reviewed by the Investigations Team the determination to file or not file a SAR.
Utilize bank provided systems for access to vendor applications such as Lexis-Nexis and Pacer along with publicly available search engines such as Google to validate identities, research individual backgrounds, obtain information on transactional counterparties, research court and legal filings and with the analysis of the transactional utilize this information to support final decisions.
Collaborate with business partners in obtaining customer information that is critical in making determinations on customer risk to the bank. Develop and maintain professional level communications that recognizes acceptable business protocols especially when a determination is made to exit and close a relationship.
Follow current processes, procedures and policies ensuring compliance with applicable Regulatory requirements regarding timely, accurate and thorough investigations are completed. Utilize High Risk business and country matrix.
Interact with Federal, State and Local law enforcement agencies in receiving and providing critical investigative and case elements that can be used in prosecuting elements of a crime.
Continue to learn and develop new skills that are transferable to other areas of the Department and can provide additional bench strength for the team.
High School diploma (4 year Degree Preferred) or equivalent with minimum of 5 years of banking or other financial services experience and a minimum of 3 years of BSA/AML or other related experience required.
Requires proficiency with bank and FIU applications including: Surveillance Monitoring, Investigations and Case Management platforms; Customer Onboarding and Customer Risk Rating platforms; Sanctions Screening Utilities and other applications.
Thorough knowledge of anti-money laundering regulatory requirements of the Bank Secrecy Act, Office of Foreign Asset Control, USA PATRIOT Act and related requirements required.
Requires proficiency with bank and FIU applications including: Surveillance Monitoring, Investigations, and Case Management platforms; Customer Onboarding and Customer Risk Rating platforms; Sanctions Screening Utilities and other applications.
Exposure to BSA/AML platform implementation, enhancement, and testing environment a plus.
Identification and mitigation of BSA/AML risk and SAR reporting requirements.
Investigate and analyze transactional activity that are indicative of unusual cash structuring, ACH related transactions, wire alerts, loan activity and activity that appears unrelated to stated business purposes.
Investigate a cross section of the entire relationship to support and provide an overall evaluation of the risk the customer presents to the Bank.
Investigate and provide comprehensive narrative to cases involving: National Security Letters (NSL’s), Law Enforcement or Judiciary Requests, External Media cases, 314(a) positive matches, Internal referrals, 314(b) requests, EDD referrals, International wires to/from bank in designated High Risk Country, OFAC Sanctions screening alerts and at the discretion of the Investigations manager.
Review previous alerts, No SARs and SARs.
Recognize what is expected or normal activity and as a Sr. Investigations Analysts, also bring into your assessment what would be a significant factor of risk that is not present and further supports your final determination to not forward to case or not file a SAR.
Training peer FIU colleagues, frontlines and operational staff as needed.
Familiarity with Enhanced Due Diligence reviews, customer risk ratings and applying risk-based analysis and reporting methodologies.
Perform Level I reviews for no-SAR cases submitted for closure. This includes a review of required documentation and agreement with the no-SAR decision.
Reviews and sends referrals to Fraud/EDD for applicable reviews as warranted
Assigned more complex investigations that are generally no-system generated (e.g. subpoenas, high risk reviews, 314(a/b).
Ability to solve practical problems and deal with a variety of concrete variables in situations when only limited standardization exists.
Where warranted and supported with appropriate documentation, recommend exiting the relationship and closure of the account.
Familiarity with:
FFIEC BSA/AML Investigations Manual
Enhanced Due Diligence, Customer Due Diligence, and Customer Risk Rating
Information Sharing
Government Reporting
Applying Risk-based Analysis and Reporting Methodologies
May lead or assist with special projects as assigned by Management.
ACAMS Certification preferred.
Related industry certification a plus.
