Deputy - OFAC Officer (HYBRID/Richmond, VA or Remote in VA/MD,NC/SC/GA/PA ONLY)

The Deputy OFAC Officer (Deputy) will serve as the Bank’s OFAC Officer in the absence of the Director- BSA/AML Officer. Throughout the normal course of business, the Deputy will be the subject matter expert and escalation point for all Sanctions-OFAC and watchlists related matters. The Deputy will be responsible for developing, implementing, and administering all aspects of the Bank’s Sanctions Compliance Program (SCP), including enterprise-wide policies and procedures to align with regulatory requirements of the Office of Foreign Assets Control and the Bank Secrecy Act, including, but not limited to, Section 314(a) of the USA PATRIOT Act. The Deputy will also serve as the Manager of the Sanctions-Watchlists team.

 

Position Accountabilities

Regulatory Compliance

• Maintain an understanding of relevant laws, regulations, guidelines, and advisories issued by OFAC, FinCEN (Financial Crimes Enforcement Network), and other regulatory bodies pertaining to economic sanctions, AML, and CTF.
• Ensure all relevant policies, procedures, and practices align with regulatory requirements and industry best practices. Conduct periodic reviews of lines of business and legal entities’ policies and procedures.
• Implement necessary changes to policies and procedures in response to regulatory updates or changes in the organization's risk profile.
• Serves as subject matter expertise to the Director of FIU for all OFAC and watchlists tasks.

 

Strategic Planning and Decision Making

• Contribute to the development of the department’s strategic objectives and initiatives related to OFAC-sanctions compliance.
• Provide strategic guidance to senior management on emerging trends, regulatory developments, and potential risks in the OFAC-sanctions landscape.
• Make informed decisions regarding sanctions-related issues, including the blocking of assets and the imposition of sanctions on individuals or entities.

 

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.
• Performs or oversees the performance of an overall OFAC-Sanctions risk assessment to identify potential vulnerabilities related to sanctions compliance
• Identify process improvements and streamlining of all OFAC-Sanctions and Watchlists compliance.
• Ensures timely disposition, and detailed, consistent documentation of all OFAC-Sanctions and Watchlists alerts, acting as required.
• Performs fuzzy logic testing through a documented period testing plan, ensuring all systems all calibrated equally and change management is fully documented and adhered to.

 

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.
• Serves as the subject matter expert for all OFAC sanctions, collaborates and guides the lines of business and applicable non-bank affiliates on the application of economic sanctions to the lines of business / applicable non-bank affiliates; with identifying control gaps and/or remediation; model validations; audits and exams; managing issues; escalating through proper governance channels as needed; and recommending corrective action plans for non-compliance.
• Works directly with Bank Operations to ensure blocked and/or restricted assets are properly titled and coded within internal systems.
• Works collaboratively with Financial Accounting on designated accounts for blocked property, reconciling each.
• Draft communications related to OFAC updates for communication to lines of business and applicable non-bank affiliates, as necessary.
• Works directly with the Systems-Data Governance Manager to identify and catalog all data feeds and systems related to OFAC-Sanctions and watchlists compliance, creating flowcharts of each system/process.
• Liaise with the Director BSA/AML Officer on all sanctions/watchlists matters

 

 

Transaction Monitoring and Investigation

• Ensure timely and thorough review, triage, and investigation of alerts generated: ensures all dispositions of watchlists alerts occur within 7 days of alerting; reporting any positive matches within the timeframe required by OFAC regulatio