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VP, AML Onboarding Manager
Banc of California
Santa Ana, CA, United States
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Description
Since 1941, Banc of California (NYSE:BANC) has provided full-service banking and lending to individuals and their businesses, families and employees throughout California and across the West.
Today, with over $10 billion in consolidated assets, we are large enough to meet our clients’ banking needs, yet small enough to care and serve them well. Banc of California’s strong balance sheet, deep community roots and commitment to lasting and meaningful relationships are the foundation for its long record of success.
JOB SUMMARY:
Responsible for the continued development, enhancement, oversight, and reporting on the Bank’s Know Your Customer (KYC), Customer Identification Program (CIP), Customer Due Diligence/Beneficial Ownership Program (CDD), and first and second line of defense customer onboarding processes and controls in support of the Enterprise Anti-Money Laundering (AML) Program. Ensures that established front line customer onboarding processes and controls adhere to the Bank’s KYC/CIP, CDD, Bank Secrecy Act (BSA), USA PATRIOT Act (USAPA), Title 31 Code Federal Regulations Chapter X, Office of Foreign Assets Control (OFAC) watch list screening, and Foreign Account Tax Compliance Act (FATCA). Performs all duties in accordance with the company’s policies and procedures, all U.S. state and federal laws and regulations, wherein the company operates.
ESSENTIAL DUTIES AND RESPONSIBILITIES:
1. Performs personnel actions including performance appraisals, disciplinary actions, and interviewing candidates for employment; supervises the daily activities of the team including, but not limited to, effective delegation of assignments, developing work schedules and providing necessary training.
2. Responsible for the overall direction, motivation, coordination and evaluation of functionalities within the unit.
3. Ensures that first and second line of defense client onboarding processes and controls are sufficiently designed, documented, and evidenced to satisfy risk, audit, and regulatory objectives, including but not limited to depository and lending onboarding.
4. Responsible for ensuring first line client onboarding complies with KYC, CIP, CDD, BSA, USAPA, OFAC, FATCA, and other AML regulations, and reviews and makes recommendations to update applicable bank governance when change is warranted. Ensures Bank’s customer onboarding controls align with bank governance and all applicable regulatory requirements.
5. Serves as the BSA/AML department’s subject matter expert and primary department contact for the BSA Liaison Middle Office function as it pertains to company wide client onboarding.
6. Ensures customers with higher risk attributes have onboarding documentation including but not limited to site inspections, automated negative news and OFAC screenings, risk attribute workflow forms, legal entity beneficial ownership (LEBOC) forms, as applicable, and all onboarding packets are completed appropriately and accurately.
7. Partners with the VP, AML Quality Control to identify trends, issues, and root causes to first line onboarding exceptions. Partners with the first line Executive Management team on remediating the root causes and providing follow-up and/or enhanced training to reduce exception levels in accordance with bank approved tolerance levels.
8. Reviews and approves new account onboarding requests for escalation to the Enhanced Due Diligence team, as needed.
9. Reviews first line exception requests via Note-to-File from the first line business unit management. Reviews and escalates to the BSA/AML Officer for review, as appropriate.
10. Manages customer onboarding escalations to the BSA/Reputation Working Group in line with Board approved risk appetite. Attends the BSA/Reputation Working Group to present the results of AML’s onboarding review and provides the BSA/AML Officer, Chief Risk Officer, and/or BSA/Reputation Working Group with a recommendation from an AML perspective.
11. Establishes new account onboarding processes and procedures for new products, services, and lines of business, as needed. Trains the front line business unit on these new processes and procedures.
12. Manages all updates to existing AML onboarding governance for changes in regulation, bank policies, standards, and/or procedures, and/or to address internal audit or quality control findings.
13. Ensures that AML Onboarding post approval reviews are conducted within the bank’s established Service Level Agreement (SLA) with the first line business units.
14. Serves as the bank’s Subject Matter Expert on the CDD/Beneficial Ownership Rule effective May 11, 2018. Ensures all Legal Entity Beneficial Ownership Certifications are appropriately completed, when applicable, in line with bank policy and regulatory laws. Provides continuous Beneficial Ownership training to the front line business units. Works in conjunction with the AML Quality Control Manager to prioritize trainings based on QC exception rates.
15. Develops, implements, oversees, and reports on customer onboarding processes, tools, policies, standards, and procedures ensuring alignment with the Bank’s Enterprise Risk Framework and the Enterprise AML Program.
16. Carries out responsibilities by promoting a risk-aware culture, ensuring efficient and effective risk and compliance management practices, identifying issues, determining root cause and taking corrective action through staff training, process or system enhancements.
17. Ensures that resources and infrastructure are adequate to support the customer onboarding program; conveys the Bank’s needs and objectives, and ensures necessary controls are in place and working as designed.
18. Works with the OCC and internal auditors to provide onboarding documentation, reports, trainings, etc. and provides timely responses to requests for information and questions.
19. Conducts quality control review to ensure staff members follow established policies and procedures, and execute deliverables within expected timeframes.
20. Works effectively with key stakeholders using strong influencing skills to resolve issues in a mutually satisfactory manner, and respective responsibilities are understood, agreed, and escalated where required.
21. Treats people with respect; keeps commitments; inspires the trust of others; works ethically and with integrity; upholds organizational values; accepts responsibility for own actions.
22. Demonstrates knowledge of and adherence to EEO policy; shows respect and sensitivity for cultural differences; educates others on the value of diversity; promotes working environment free of harassment of any type; builds a diverse workforce and supports affirmative action.
23. Follows policies and procedures; completes tasks correctly and on time; supports the company’s goals and values.
24. Performs the position safely, without endangering the health or safety of themselves or others and will be expected to report potentially unsafe conditions. The employee shall comply with occupational safety and health standards and all rules, regulations and orders issued pursuant to the OSHA Act of 1970, which are applicable to one’s own actions and conduct.
25. Performs other duties and projects as assigned.
Banc of California is an equal opportunity employer committed to creating a diverse workforce. All qualified applicants will receive consideration for employment without regard to age (40 and over), ancestry, color, religious creed (including religious dress and grooming practices), denial of Family and Medical Care Leave, disability (mental and physical) including HIV and AIDS, marital status, medical condition (cancer and genetic characteristics), genetic information, military and veteran status, national origin (including language use restrictions), race, sex (which includes pregnancy, childbirth, breastfeeding and medical conditions related to pregnancy, childbirth or breastfeeding), gender, gender identity, gender expression, and sexual orientation.
Qualifications
ESSENTIAL KNOWLEDGE, SKILLS, AND ABILITIES:
• Demonstrates knowledge of, adherence to, monitoring and responsibility for compliance with state and federal regulations and laws as they pertain to this position including but not limited to the following: Regulation Z (Truth in Lending Act), Regulation B (Equal Credit Opportunity Act), Fair Housing Act (FHA), Home Mortgage Disclosure Act (HMDA), Real Estate Settlement Procedures Act (RESPA), Fair Credit Reporting Act (FCRA), Bank Secrecy Act (BSA) in conjunction with the USA PATRIOT Act, Anti-Money Laundering (AML) and Customer Identification Program (CIP), Right to Financial Privacy Act (RFPA, state and federal) and Community Reinvestment Act (CRA)
• Advanced knowledge of production analysis and report writing environments
• Advanced knowledge of BSA/AML regulations, requirements, research techniques, and tools
• Expert knowledge of the end to end KYC, CIP, and CDD onboarding processes
• Knowledge of International Banking as well as various non-retail banking products and services including; deposit, investment, treasury and cash management, equipment lending, commercial real estate lending, and credit products, foreign currency exchange or other financial instruments a plus
• Understanding of complex corporate structures and CIP and additional due diligence and documentation requirements including ultimate Beneficial Ownership information
• Thorough understanding of the regulatory environment affecting financial institutions and applicable regulations impacting financial crimes and fraud prevention
• Advanced knowledge of BSA, USAPA, Title 31 Code Federal Regulations Chapter X regulations and requirements, and OFAC Sanctions and experience in Sanctions investigations, for various customer types
• Strong knowledge of and proficiency with AML transactional monitoring and case management systems
• Effective planning, organizational, time management, issue resolution and decision-making skills
• Strong relationship development and leadership skills
• Solid presentation and reporting skills of in-house tools and databases; heavy understanding within Microsoft Office (Excel, PowerPoint, etc.)
• Intermediate math skills; calculate interest and percentages; balance accounts; add, subtract, multiply and divide in all units of measure, using whole numbers, common fractions and decimals; locate routine mathematical errors; compute rate, ratio and percent, including the drafting and interpretation of bar graphs
• Effective organizational and time management skills
• Exceptional oral, written and interpersonal communication skills with the ability to communicate complex information accurately, clearly and quickly
• Ability to collaborate to achieve objectives and influence others, build teams and communicate effectively with Senior Management
• Ability to assess processes (including process mapping), identify and drive improvement execution, and have relationship management and conflict resolution skills
• Ability to monitor new regulatory guidance/pronouncements that may directly or indirectly affect the department and recommend and/or implement any necessary changes to maintain compliance with the new law, rule, or regulation
• Ability to read, analyze and interpret common technical journals, financial reports and legal documents
• Ability to make decisions that have significant impact on the immediate work unit and cross functional departments
• Ability to make informal and formal presentations, inside and outside the organization; speaking before assigned team or other groups as needed
• Ability to deal with complex difficult problems involving multiple facets and variables in non-standardized situations
EDUCATION, EXPERIENCE AND/OR LICENSES:
• Bachelor’s Degree preferred.
• Seven (7) to Ten (10) years’ experience in the banking and/or financial services industry.
• Three (3) to Five (5) or more years in a managerial, supervisory, or team lead role.
• Certified Anti-Money Laundering Specialist (CAMS) certification required; CPA, CFCS, and/or CFE certification(s) a plus.