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OliBank is building a digital-first financial system with a mission to make managing finances as easy as possible. The company operates as a FinCEN-registered Money Services Business (MSB) with a Puerto Rico International Financial Entity (IFE) license.
You will serve as the Designated BSA/AML Officer, owning the entire risk-based Bank Secrecy Act and Anti-Money Laundering compliance program. This is a strategic, high-autonomy role reporting directly to the Board.
Key responsibilities include:
**BSA/AML Program Ownership**: Design, implement, and maintain the risk-based BSA/AML compliance program covering Customer Identification Program (CIP), Know Your Business/Customer (KYB/KYC), beneficial ownership identification, Enhanced Due Diligence (EDD), ongoing transaction monitoring, and recordkeeping across both MSB and bank programs. You hold Suspicious Activity Report (SAR) decisioning authority, manage SAR filing timelines (31 CFR 1020.320), oversee continuing-activity reviews, and handle FinCEN 314(a) searches within the 14-day window.
**Sanctions & Screening Governance**: Direct OFAC sanctions list screening ingestion and reconciliation, manage ITA Consolidated Sanctions List and EU/UK sources, own OFAC 50 Percent Rule handling, conduct pre-submission beneficiary screening, and manage fuzzy-match dispositions. You are responsible for OFAC block/reject handling (31 CFR 501.603/601.604) with 10-business-day reporting obligations and fail-closed behavior during screening outages.
**Client Lifecycle & Risk Assessment**: Evaluate onboarding decisions, identify EDD triggers (high-risk jurisdictions, complex ownership structures, volume anomalies, PEP/sanctions exposure), and assess transaction activity for compliance risk. Proactively audit onboarding processes, KYB artifacts, monitoring alerts, and risk-scoring dispositions; document findings, remediation actions, and residual risk.
**Controls & Culture**: Build systemic internal controls with forcing functions rather than one-off customizations. Own the compliance training program for staff, engineering/CIS teams, and Board orientation. Manage independent testing, audit remediation, examiner requests (OCIF and IRS BSA exams for MSBs), and the residual-risk register.
**Vendor & Counterparty Oversight**: Provide compliance sign-off on vendor reviews where BSA/AML screening or monitoring is implicated.
You will report directly to the Board on program health, trends, and deficiencies—focusing on metrics and trends, not case-file details. The role emphasizes integrity, independence of judgment, and the ability to veto decisions when necessary.
**Requirements**
- 3+ years of BSA/AML compliance experience in a regulated financial institution
- Direct experience with a Puerto Rico IFE and OCIF examination cycle (required)
- Hands-on SAR lifecycle experience: investigation, determination memos, filing clocks, continuing activity, and confidentiality protocols; must be able to evidence SAR decisioning authority
- Working knowledge of BSA recordkeeping, funds-transfer recordkeeping (§1010.410), FinCEN 314(a), OFAC administration, and MSB obligations (31 CFR Part 1022 vs. bank Part 1020/CIP differences)
- Experience with transaction monitoring and risk-scoring systems, KYB/KYC vendors, and audit of alert dispositions with false-positive rationale discipline
- 2+ years of risk management and/or financial-crimes audit experience
- Strong research, writing, and Board-level communication skills
- Fluent English required; Spanish a strong plus (OCIF/market reality)
- University degree in law, finance, business administration, or related field (JD or advanced degree a plus, not required)
**Strongly Preferred**
- Professional certification: CAMS, CGSS, CRCM, or equivalent
- Stablecoin and cross-border payments experience
- Data-protection literacy (GDPR concepts); privacy-framework experience is a plus
