Legal & Compliance Department - Financial Intelligence Unit (FIU) External Engagement Associate/AVP

Introduction

Established in 1912, Bank of China is one of the largest banks in the world, with over $3 trillion in assets and a footprint that spans more than 60 countries and regions. Our long-term outlook, institutional weight and global breadth provide our clients with a stable and reliable financial partner, whether in Corporate or Personal Banking or our Trade Services, Commodities, Financial Institutions and Global Markets lines of business.

Overview

The FIU External Engagement Associate/AVP is primarily responsible for assisting FIU-EET in investigating and responding to external inquiries; conducting enhanced due diligence reviews and research; escalating unusual activity and risk to appropriate parties in compliance with the Bank Secrecy Act (BSA), The USA PATRIOT Act, US Treasury AML guidelines, OFAC, SEC, FINRA, FRB, FinCEN, and SAR requirements; and responding to AML related inquiries regarding FinCEN 314(a), 314(b), fraud and law enforcement requests. Special Assignments by Senior Management are also acknowledged as part of the EET workflow.

Responsibilities

Include but are not limited to:  

 

Request Analysis

• Conduct time-sensitive and meticulous first-response investigations, analyzing money laundering activity and/or suspicious financial activity across multiple jurisdictions, utilizing a wide analytical review and research tools.
• Conduct manual analysis to make determination on responsiveness of results and document in match log.
• Conduct customer relationship searches in applicable systems and document in match log.
• Act as a back-up to Team Lead to perform BSA Officer reach-outs, when applicable.

Request Administration

• Maintain request folders in user-access only folders which include Correspondence, Wire Searches, Customer Relationship Searches and AML Follow-up.
• Administer generalized Confidentiality Agreements for work steam administration and on special projects.
• Administer ADC Wire Searches with ADC and provide space for information sharing in user-access only folders.
• Data cleaning and file naming conventions of ADC wire returns.
• Create user access only folders within the K Drive for cross-department information sharing on requests.
• Communicate request status updates and results with Team Lead on a continuous basis.
• Prepare draft meeting minutes when required for review and dissemination by Team Lead.

Request Risk Evaluation & Escalation

• Complete escalation review with required documentation and unusual activity checklist or draft closure narrative within thirty (30) days of inquiry response.
• Manually divide out escalatable wire(s) and other responsive information by subject.
• Review and include BSA Responses of potential customer matches to give a holistic approach to SAR Team.
• Update escalation logs appropriately for tracking purposes and to ensure proper metric reporting.

Transaction Monitoring:  AML Review of Flagged Bank Returns & L2 Investigation Reviews

• Conduct AML review of bank returns in addition to assisting the FIU Team in the review of the different types of investigations when required (e.g. Strategic Intelligence, Level II Investigations) for potential suspicious activity as it relates to the Bank’s risk appetite and regulations.
• When required, review L2 Investigations and determine whether a SAR should be filed or a Decision Not to File (Reasonable) Case is Warranted.
• For AML Review of Bank returns, conduct initial investigation by reviewing alerts for unusual activities following the bank’s methodology and decide whether to escalate or clear the alert.
• Disposition and fully document all investigations, within the Case Management Tool in a timely manner (and include all supporting data, analysis, narrative and rationale for disposition).
• Report and/or escalate any unusual transaction(s) to the Investigations team in a timely fashion. 

Metrics, Reporting & Training

• Keep work stream status logs up to date to demonstrate completion and need for follow-up.
• Draft reports for Compliance Risk Metric Group’s monthly “Heatmap”.
• Ad hoc assignment reporting to Senior Management depending on the complexity of the bank and risk to the bank.
• QA Reporting, when reviewing another’s work product.
• Internal reporting of hours worked on assignments.
• Compile annual/ad hoc training materials for annual External Engagement Training and FIU Alert training for team members, and new hires.
• Complete mandatory institutional trainings and continuing education as required by Training Department.
• Stay informed of related regu