The Deputy OFAC Officer (Deputy) will serve as the Bank's OFAC Officer in the absence of the Director- BSA/AML Officer. Throughout the normal course of business, the Deputy will be the subject matter expert and escalation point for all Sanctions-OFAC and watchlists related matters. The Deputy will be responsible for developing, implementing, and administering all aspects of the Bank's Sanctions Compliance Program (SCP), including enterprise-wide policies and procedures to align with regulatory requirements of the Office of Foreign Assets Control and the Bank Secrecy Act, including, but not limited to, Section 314(a) of the USA PATRIOT Act. The Deputy will also serve as the Manager of the Sanctions-Watchlists team.

Position Accountabilities

Regulatory Compliance

• Maintain an understanding of relevant laws, regulations, guidelines, and advisories issued by OFAC, FinCEN (Financial Crimes Enforcement Network), and other regulatory bodies pertaining to economic sanctions, AML, and CTF.
• Ensure all relevant policies, procedures, and practices align with regulatory requirements and industry best practices. Conduct periodic reviews of lines of business and legal entities' policies and procedures.
• Implement necessary changes to policies and procedures in response to regulatory updates or changes in the organization's risk profile.
• Serves as subject matter expertise to the Director of FIU for all OFAC and watchlists tasks.

Strategic Planning and Decision Making

• Contribute to the development of the department's strategic objectives and initiatives related to OFAC-sanctions compliance.
• Provide strategic guidance to senior management on emerging trends, regulatory developments, and potential risks in the OFAC-sanctions landscape.
• Make informed decisions regarding sanctions-related issues, including the blocking of assets and the imposition of sanctions on individuals or entities.

Risk Assessment and Mitigation

• Maintain awareness of emerging sanctions risks, assess how they may impact the Bank, and develop and implement risk mitigation strategies to address identified risks effectively.
• Performs or oversees the performance of an overall OFAC-Sanctions risk assessment to identify potential vulnerabilities related to sanctions compliance
• Identify process improvements and streamlining of all OFAC-Sanctions and Watchlists compliance.
• Ensures timely disposition, and detailed, consistent documentation of all OFAC-Sanctions and Watchlists alerts, acting as required.
• Performs fuzzy logic testing through a documented period testing plan, ensuring all systems all calibrated equally and change management is fully documented and adhered to.

Cross-functional Collaboration and Communication

• Collaborate with other departments, including Legal, Risk Management, Systems/Data Governance, Internal Audit, and Business Units to address sanctions-related matters and ensure a coordinated approach to compliance.
• Liaise with law enforcement agencies, government entities, and industry associations on sanctions-related investigations, questions, intelligence sharing, and industry initiatives.
• Serves as the subject matter expert for all OFAC sanctions, collaborates and guides the lines of business and applicable non-bank affiliates on the application of economic sanctions to the lines of business / applicable non-bank affiliates; with identifying control gaps and/or remediation; model validations; audits and exams; managing issues; escalating through proper governance channels as needed; and recommending corrective action plans for non-compliance.
• Works directly with Bank Operations to ensure blocked and/or restricted assets are properly titled and coded within internal systems.
• Works collaboratively with Financial Accounting on designated accounts for blocked property, reconciling each.
• Draft communications related to OFAC updates for communication to lines of business and applicable non-bank affiliates, as necessary.
• Works directly with the Systems-Data Governance Manager to identify and catalog all data feeds and systems related to OFAC-Sanctions and watchlists compliance, creating flowcharts of each system/process.
• Liaise with the Director BSA/AML Officer on all sanctions/watchlists matters

Transaction Monitoring and Investigation

• Ensure timely and thorough review, triage, and investigation of alerts generated: ensures all dispositions of watchlists alerts occur within 7 days of alerting; reporting any positive matches within the timeframe required by OFAC regulation; and escalate to the EDD Investigations group for additional review and determination of potential suspicious activity.
• Investigates potential sanctions issues by partnering with relevant lines of business, Compliance, Legal, and Operations or applicable non-bank affiliates to determine validity.
• Ensures timely responses to all OFAC concerns raised by the business lines / applicable non-bank affiliates

Reporting and Documentation

• Maintain thorough documentation of all sanctions-related activities including screening results, investigations, reports, regulatory correspondence, and training materials.
• Prepare and submit regulatory reports to OFAC, FinCEN, and other relevant authorities as required by law or regulation.
• Drafts for review and files reports of blocked and/or transactions to OFAC within 10 days of identifying a positive match.
• Drafts for review annual blocked property report for submission to OFAC prior to September 30^th
• Creates quarterly metrics to measure the Bank's, and applicable legal entities' compliance with OFAC-Sanctions and Watchlists requirements, to support improvement of FIU Sanctions-Watchlists functions, and to keep the Director of FIU abreast of the state of the Sanctions compliance program.
• Provide documentation and support during regulatory examinations and audits.

Internal Controls and Governance

• Establish and maintain effective internal controls to ensure the integrity and accuracy of sanctions screening processes.
• Responsible for ensuring all watchlists updates are conducted successfully and in a timely manner.
• Responsible for remediation of all outstanding audit and regulatory issues assigned.
• Regularly assess the effectiveness of the sanctions compliance program and internal controls and make recommendations for improvements, as needed.
• Responsible for maintaining appropriate resources to create a sustainable, scalable, and effective Program.
• Participate in internal committees or working groups focused on risk management, compliance, or regulatory affairs.

Training and Awareness

• Develop and deliver training to raise awareness and understanding of OFAC/sanctions compliance requirements and best practices, as needed.
• Create and provide, directly or indirectly, in coordination with the FIU Governance - 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 raising awareness of sanctions-related risks and obligations.

Vendor Management and Technology Oversight

• Participate in the evaluation and selection of third-party vendors and technology solutions to support sanctions screening and compliance.
• Monitor the performance of vendors and technology providers, ensuring they adhere to contractual obligations and meet regulatory standards.
• Coordinate with IT and data management teams to implement and maintain effective sanctions screening systems.
• Ensure all systems utilized for S sanctions watchlists screenings are calibrated appropriately, performing testing and validation of methodology applied for screening.

Ethical Conduct and Professionalism

• Uphold the highest standards of professional ethics, integrity, and confidentiality in all activities related to sanctions compliance and financial crime prevention.
• Serve as a role model for compliance and ethical behavior within the organization, fostering a culture of integrity and accountability.

Organizational Relationship

This position reports to the Director of BSA AML Officer

Supervision of Others - Yes

Position Qualifications

Education & Experience

• Bachelor's degree in criminal justice, Business or a related field is preferred, but not required.
• Certification as a compliance professional (CGSS, CAFP, CAMS) required.
• Must have 7 or more years of Sanctions (primarily OFAC) experience.
• At least 2 years' experience with model risk management activities related to OFAC model tuning and implementation.
• At least 2 years managing staff in financial crimes operational and policy capacities.
• Experience selecting, implementing, and managing OFAC screening platform(s) and working effectively with vendors.
• Experience in leading or managing compliance teams, projects, or initiatives, demonstrating the ability to oversee sanctions compliance activities effectively and drive organizational change.
• Strong knowledge of relevant laws, regulations, and industry guidelines related to economic sanctions, AML, CTF, and financial crime prevention is essential.

Knowledge & Skills

• Strong understanding of OFAC sanctions programs, executive orders, and related guidance. Ability to research and interpret sanctions regulations.
• Excellent communication, interpersonal, and leadership skills for effectively engaging with internal stakeholders, external partners, and regulatory authorities, as well as for providing guidance and training to staff members on sanctions compliance matters.
• Knowledge of, and ability to apply, Sanctions / AML rules and regulations to prevent or report Sanctions-related activities and money laundering in the financial services industry.
• Demonstrated ability to interact with management and other business lines with tact and diplomacy while achieving stated objectives.
• Ability to make and support sound judgement calls and decisions under time constraints.
• Must be able to work effectively with internal auditors, regulatory bodies and other entities with oversight functions.
• Ability to interact directly with OFAC, preparing appropriately for the conversation to include through research of sanction and/or alert PRIOR to initiating call to be fully prepared to provide supporting documentation, state facts, etc.
• Knowledge of Fuzzy Logic application and testing of systems for OFAC compliance.
• Advanced written, oral, data analytics, and interpersonal skills with high attention to detail and strong analytical, problem solving and logical reasoning.
• Working knowledge of financial institution operations and banking products.
• Advanced PC skills including word processing, spreadsheet, and internet research.
• A strong working knowledge of AML transaction monitoring systems and processes.
• Strong practical knowledge of laws applicable to money laundering including BSA, USA PATRIOT Act, Department of U.S. Treasury OFAC requirements, and SAR reporting.
• Excellent analytical and problem-solving skills to navigate complex sanctions scenarios.
• Meticulous attention to detail and the ability to maintain accurate documentation.

Salary offered will be based on several factors including but not limited to education, work experience, certifications, etc. This position is also eligible to participate in either an applicable incentive compensation plan for the position or a discretionary profit sharing bonus program. General information on our comprehensive benefits package can be found by visiting .

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