Deputy BSA and Deputy OFAC Officer - Hybrid/Remote

Job Description

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