Director, AML/CFT Risk Assessment

About the role

The Director, AML/CFT Risk Assessment and Program Effectiveness role is responsible for leading the design, execution, documentation and continuous enhancement of a dynamic, risk-based AML/CFT risk assessment framework that supports the bank’s BaaS and embedded finance activities.

Serves as a subject matter expert and cross-functional partner, working closely with the first, second, and third lines of defense to identify, assess, document and help mitigate financial crimes risk.

Ensures the framework is effective, reasonably designed, and calibrated to the bank’s size, complexity, risk profile, FinCEN AML/CFT priorities, regulatory expectations, and evolving illicit finance risks.

Evaluates new products, services, partners and business initiatives, ensuring that AML/CFT risk considerations are embedded in strategic decision-making and that appropriate mitigating controls are defined and in place.

Responsibilities

• Risk Assessment
• Help direct and manage the enterprise-wide AML/CFT risk assessment program, including periodic and event-driven refresh cycles, methodology updates, and governance reporting (ex., board, executive committees, etc.)
• Oversee and execute the risk assessment process to identify and evaluate the bank’s AML/CFT risks across customers, products, services, geographies, delivery channels, partners, and transaction activity, translating risk assessment outputs into actionable findings, residual risk ratings, and control gap analyses for senior management and regulatory audiences
• Incorporate, as appropriate, FinCEN AML/CFT priorities, emerging typologies, law enforcement priorities, regulatory feedback, audit findings, monitoring results, SAR/CTR trends, customer due diligence information, and third-party/partner risk indicators into the risk assessment methodology
• New Product & Business Initiative Review
• Lead the AML/CFT new product, new partner, and business initiative review process, serving as a key second-line risk reviewer/approver within the bank’s product governance, third-party risk management, and risk intake framework
• Conduct comprehensive AML/CFT risk assessments for proposed products, partnerships, distribution channels, and market expansions prior to approval and launch
• Partner with business development, product management, legal, and compliance teams to identify AML/CFT risk drivers and define required mitigating controls
• Govern and oversee conditions of approval, compensating controls, risk acceptance criteria, launch readiness requirements, post-launch monitoring expectations, and escalation triggers for higher-risk or novel initiatives
• Cross-Functional Control & Governance
• Collaborate with 1LoD, 2LoD compliance, technology, operations, and internal audit teams to identify control gaps and ensure appropriate remediation
• Advises business line leaders on AML/CFT obligations and translates regulatory requirements into operational control standards
• Represents the AML/CFT risk function in enterprise risk committees, new product committees, and other relevant governance forums
• Contributes to the development and maintenance of AML/CFT policies, standards, and procedures
• Regulatory Engagement & Examinations
• Serve as a primary point of contact for AML/CFT risk assessment-related inquiries, along with internal /external reviews
• Prepare and present risk assessment documentation, program narratives, and control evidence for audit and regulatory exams
• Monitor regulatory developments and industry guidance to ensure program frameworks remain up to date
• Team Leadership & Development
• Manage, mentor, and develop a team of AML/CFT risk professionals, fostering a culture of analytical rigor, accountability, and continuous improvement
• Establish team priorities, align resources to workload demands, and drive timely execution of risk assessment deliverables
• Serve as a thought leader within the AML/CFT function and contribute to the broader financial crimes compliance strategy

Qualifications

• Bachelor’s degree required
• Advanced degree in Finance, Law, Business Administration, or a related field preferred
• AML/CFT or financial crimes certification preferred
• 8+ years of progressive AML/CFT compliance experience, with at least 4 years in a risk, program management, or leadership role
• Direct experience in regulated banking environments; experience within BaaS, fintech partnership banking, or OCC-regulated institutions strongly preferred
• Demonstrated experience owning and executing enterprise AML/CFT risk assessments and new product review processes
• Deep knowledge of the Bank Secrecy Act, USA PATRIOT Act, FinCEN regulations, FFIEC AML/CFT Examination Manual, and OCC supervisory expectations
• Proficiency in assessing AML risk across diverse product types including prepaid, commercial banking, payments, lending, and deposit products
• Familiarity with transaction monitoring systems, case management platforms, and risk assessment tooling

Preferred Qualifications

• Direct BaaS or partner bank experience, with knowledge of compliance challenges associated with fintech relationships and program management
• Experience with prepaid card issuing programs, commercial banking, or lending-related BSA/AML risk assessment
• Experience leading AML/CFT program transformation or enterprise-scale compliance build-outs