Director, BSA High Risk Customer Review
PathwardAbout the role
We are a hybrid, remote-office company dedicated to growing our talent anywhere!
We have onsite locations in: Sioux Falls, SD, Scottsdale, AZ, Louisville, KY, Troy, MI, Franklin, TN, Easton, PA.
At Pathward, we take tremendous pride in our purpose to create financial inclusion for all™. We are a financial empowerment company that works with innovators to increase financial availability, choice, and opportunity for all. We strive to remove barriers that traditional institutions put in the way of financial access, and promote economic mobility by providing responsible, secure, high quality financial products.
We are a team of problem solvers and innovators who celebrate our differences and know that our unique perspectives make us stronger and well-positioned for success. We celebrate, and embrace, our team members through our *HUMBLE*HUNGRY*SMART approach, and we believe that we are strongest when we embrace the voices of our employees, customers, partners, and the communities we serve.
About the Role:
The Director of BSA High Risk Customer Review leads the team responsible for performing customer due diligence (CDD)/enhanced due diligence (EDD) (“high risk”) reviews on the Bank's higher-risk customers across all business lines. This role ensures that high risk customer relationships are thoroughly assessed, appropriately documented, and continuously monitored in accordance with BSA/AML regulatory requirements and the Bank's risk appetite.
The Director is responsible for building and developing a team capable of executing complex customer reviews spanning retail banking, commercial lending, prepaid/issuing programs, and Banking-as-a-Service (BaaS) partnerships. Beyond day-to-day review execution, this role is expected to establish and refine the processes, procedures, and quality standards that govern the high risk review function, ensuring consistency, scalability, and regulatory defensibility as the Bank continues to grow.
What You Will Do:
High Risk Customer Review Program
- Lead the execution of due diligence reviews for high risk customers across all business lines, including retail banking, commercial lending, prepaid/issuing programs, and BaaS partnerships
- Develop and maintain standardized review procedures, templates, quality standards, and escalation protocols that ensure consistency and regulatory defensibility across business lines
- Monitor review volumes, aging, and completion metrics to ensure program expectations are met and identify capacity needs proactively
Process Development & Cross-Business Line Coordination
- Design and build the operational framework for the high risk review function, including workflows, case management standards, documentation requirements, and quality assurance processes
- Identify opportunities to improve review efficiency and effectiveness through process refinement, automation, and better use of available tools and data sources
- Partner with business line leaders, customer onboarding teams, and transaction monitoring and investigations teams to ensure high risk reviews reflect relevant business context and compliance findings
- Stay current on regulatory guidance, enforcement actions, and industry best practices and incorporate relevant developments into the program
Team Leadership & Development
- Build, lead, and develop a team of high risk review analysts and specialists with clear performance expectations, quality benchmarks, and professional development paths
- Provide coaching, mentoring, and ongoing training to build team competency across the Bank's business lines, with particular emphasis on BaaS, issuing, and lending risk reviews
- Manage hiring, onboarding, and succession planning to maintain adequate staffing and capability
Regulatory & Stakeholder Engagement
- Represent the high risk review function during regulatory examinations, internal audits, and external assessments
- Prepare reporting for senior leadership on review activity, trends, and program health
- Partner with other BSA Department stakeholder groups to ensure alignment with the Bank's broader BSA/AML compliance framework, customer risk rating methodology, and suspicious activity monitoring processes
What You Will Need:
- Bachelor's degree required
- Advanced degree (JD, MBA, or master’s in a related field) preferred.
- CAMS, CFCS, or similar certification preferred
- 10+ years of experience in BSA/AML compliance, with significant focus on enhanced due diligence, high risk customer management, or customer risk review programs
- At least 5 years of experience directly leading teams of eight or more compliance
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