BSA-AML Analyst - Firstrust Bank

Objective

Act in a universal role for BSA/AML and fraud and will support the design and execution of the monitoring program, including but not limited to transaction monitoring, investigations, identification of trends and patterns, and ensuring that the ORM team has the necessary information available to support policy development and decision-making.  Understand regulatory requirements and apply them to our business model to ensure the effective execution of the program. Utilize various systems/applications, which includes our data warehouse, core Miser BI, and automated compliance software Abrigo.  Assist in the investigation of potential suspicious activity in or related to customer accounts from an BSA/AML and fraud perspective, and prepare reports that meet internal and regulatory standards, concerning such activity.  Communicate clearly with bankers and customers in the conduct of investigations and monitoring efforts and educate and advise lines of business to ensure full compliance.  Cross-train on various operations across the ORM Department as needed and keep abreast of the applicable regulatory matters affecting the compliance program. 

Firstrust Bank is an Affirmative Action Contractor and is an Equal Opportunity Employer.

Minority/Female/Disabled/Veteran

Responsibilities/Duties

• Create and execute periodic and ongoing tuning methodology for our monitoring systems.
• Create and run sequel queries to support monitoring activities outside of the BSA/AML system.
• Perform OFAC routine within required timeframes for all required files including but not limited to:

• International ACH Transactions (IAT)
• Customer File
• Subsidiary Customer Files
• Employee File
• Monetary Instrument Payee File

Investigate any matches, notify appropriate area, and escalate issues to VP – BSA/AML   Manager.

• Conduct review of Monetary Instrument logs from branches to ensure proper documentation of all cash related transactions and proper completion by branch staff.

• Responsible for conducting the daily process in the BSA/AML monitoring system to reconcile Currency Transaction Reporting (CTR) including ensuring all reportable transactions are accounted for and necessary forms are completed properly and prepared for filing with FinCEN within the required timeframes.

• Follow up on reported CTR errors from IRS and amend forms as required.

• Prepare and complete SAR filings including, transaction activity overviews, narratives, and completion of the form in the BSA/AML system.

• Responsible to review and resolve any issues that are identified on all reports related to BSA/AML compliance including, but not limited to:

• Non-Validated transactions for ACH, ATM, Misc., RDC, Teller, and Wire feeds
• Import Summary

• Responsible for monitoring reports generated from the Miser core system and Abrigo’s system to identify suspicious activity, conduct investigation and recommend appropriate action.  Reports include but are not limited to:

• Large Cash Transactions
• Large ATM deposits
• Monetary Instruments Purchased with Cash
• CD’s Closed
• New Loans
• Closed Loans
• Wire Report
• CTR Reconciliation

• Conduct reviews of the BSA/AML system reports and audit log to confirm all required files have been imported from the core and various ancillary systems.

• Conduct reviews of the BSA/AML system to confirm that all scenario engine runs were successful and assign alerts to appropriate staff members.

• Review, investigate and decision the alerts and cases that have been generated by BSA/AML systems, notate, and escalate any findings to the appropriate ORM employee.

• Conduct a first line analysis of alerts related to online banking transactions for external transfers and person to person transfers utilizing internal systems and research tools.  When necessary, escalate to Fraud team for further investigation.  

• Reviewing and analyzing both specific transactions and trends in customer accounts and identify and investigate activity that is not consistent with such customer’s expected activities. 

• Review wire reports and decision each wire whether it is international or domestic and enter incoming international wires into system to track transfers from GL account to customer account using daily reports.

• Conduct daily proactive reviews of reports related to ATM deposits, E-funds alerts and kiting to mitigate possible losses. 

• Assist in the review of any return mail presented by Account Services for questionable activity.

• Perform 314(a) scans in accordance with the regulation and report as required.

• Review reports for missing CIP information and follow-up with proper staff to obtain the missing information. 
• Monitor the Due Diligence Manager (DDM) module to ensure proper completion for all new accounts and report any missing/incomplete information to proper staff for updating of forms.

• Create reports of all missing DDM information and distribute to responsible parties.

• Process DDM exceptions for proper tracking.

• Review Beneficial Ownership (BO) forms to ensure proper completion for all new accounts and report and missing/incomplete information to proper staff for updating of forms.

• Review reports for missing BO forms and follow-up with proper staff to complete the forms.

• Process BO exceptions for proper tracking.

• Create reports for identification of new business customer types and new higher risk type businesses to compare them to similar business accounts in their industry type.

• Complete data entry of required fields to ensure proper:

• Classification of business types for NAICS codes.
• Tagging for identification of higher risk services and events on customer profiles.

• Assist branch personnel with any issues related access or the entry of data into all systems connected to the BSA/AML monitoring system including CTR processing, DDM process, and the Monetary Instrument log.

• Run a Sequel query to identify credit card transactions from the previous day and reconcile with transactions that were imported into the BSA/AML system.

• Update account tags as needed in the BSA/AML system for those related to, but not limited to:

• ACH origination customers
• RDC customers
• Private ATM customers
• Money Service Business customers
• NRA customers
• PEP customers

• As needed, assist VP – BSA/AML Manager with:

• Law Enforcement requests
• 314(b) requests
• BSA/AML system upgrades
• Lexis Nexis AML software searches
• Keyword list additions/deletions

• Complete reviews of monthly reports including, but not limited to:

• Keyword search reports (MSB, MRB, Internet Transfer, Private ATM, Human Trafficking/Smuggling, Online Gambling)
• Loans closed within 6 Months of Opening
• W-8’s
• Duplicate Address
• Cenlar Query
• Open/Closed Loan Query
• RDC Query

• Complete reviews of semi-annual reports including:

• High Risk Accounts
• High Risk Account DDM’s
• High Risk Accounts Missing DDM’s

• Assist VP – BSA/AML Manager with annual customer reviews including, but not limited to:

• On-site MSB reviews
• CTR independent/dependent businesses
• CTR exemptions
• PEP accounts
• Department procedure updates
• Private ATM customers
• W-8 customers

• Participate on assigned compliance projects. 

• Perform and assist with other duties as assigned by VP – BSA/AML Manager.

• Maintain deep and current knowledge of the Bank Secrecy Act and all related regulations.

Essential Functions

While performing the essential functions of this position, the employee is regularly required to detect and convey suspicious activity, communicate policy and be able to exchange information.  Sedentary work involves sitting most of the time; however, some mobility may be necessary to retrieve files or move light objects.  The employee is required to operate a computer terminal to compile and collect data, prepare reports, and research current regulations.  This position involves extensive reading. 

Knowledge - Skills & Abilities

• Knowledge of bank products and processes.
• Must be well organized and detail oriented
• 3 +years banking experience required with background or experience in accounting a plus.
• Must possess good analytical skills.
• In depth knowledge of the Bank Secrecy Act, Patriot Act, and related regulations.
• Excellent communications and interpersonal skills.
• Excellent time management skills.
• Proficient with software applications with an emphasis on database management.
• Intermediate knowledge of the Microsoft Office (Word, Excel, and Outlook).