Financial Crimes Quality Assurance Analyst
About the role
The Financial Crimes Quality Assurance (QA) Analyst is responsible for executing within the quality assurance program focused on Second Line of Defense (2LoD) Financial Crimes activities, including oversight, review, challenge, and governance functions across BSA/AML, Sanctions, and Fraud.
This role ensures that 2LoD processes—such as alert oversight, customer risk rating governance, policy interpretation, and escalation decisions—are performed with consistency, accuracy, and in alignment with regulatory expectations and internal standards. The Analyst will assess the effectiveness of 2LoD outputs, provide credible challenge within Compliance, and deliver insights to strengthen oversight and risk management practices.
Responsibilities
- QA Review Execution
- Perform detailed QA reviews of 2LoD casework, memos, and decisions to evaluate:
- Accuracy and completeness
- Appropriateness of risk-based judgments
- Alignment with internal standards and regulatory expectations
- Evaluate the quality of 2LoD oversight, including whether issues are appropriately identified, escalated, and resolved
- Identify inconsistencies in decision-making and gaps in challenge or governance
- Thematic & Horizontal Reviews
- Conduct horizontal reviews across 2LoD outputs to identify:
- Systemic weaknesses in oversight practices
- Trends in ineffective challenge or missed escalation opportunities
- Inconsistencies in policy interpretation
- Develop insights into emerging risks and control blind spots within 2LoD
- Framework & Methodology Development
- Assist with the development and maintenance of QA methodologies specific to 2LoD activities, including:
- Test scripts tailored to oversight and challenge functions
- Defect taxonomy focused on governance, escalation, and decision quality
- Scoring frameworks to assess effectiveness of 2LoD outputs
- Ensure clear differentiation between 1LoD execution errors and 2LoD oversight deficiencies
- Issue Management & Reporting
- Document QA findings with clear articulation of:
- Gaps in 2LoD oversight, challenge, or governance
- Root cause and impact on risk management effectiveness
- Assign severity ratings based on risk exposure and regulatory implications
- Track and validate remediation of identified issues within Compliance
- Stakeholder Engagement & Credible Challenge
- Provide independent challenge within the 2LoD function, ensuring high standards of oversight and accountability
- Support regulatory exams by demonstrating the effectiveness and rigor of 2LoD oversight and QA practices
- Continuous Improvement
- Identify opportunities to enhance 2LoD QA through:
- Standardization of oversight practices
- Enhanced documentation and governance protocols
- Use of data analytics to identify anomalies or inconsistencies in 2LoD outputs
- Bachelor’s degree in Finance, Business, Risk Management, or related field
- 3–7+ years of experience in Financial Crimes (AML, Sanctions, Fraud), with direct experience in:
- 2LoD Compliance / Financial Crimes oversight, or
- Quality Assurance / Testing of Financial Crimes functions
- Strong knowledge of:
- BSA/AML and sanctions regulatory expectations
- 2LoD roles and responsibilities within a three lines of defense model
- Financial crime risk management frameworks and governance practices
- Experience reviewing complex financial crime cases and providing oversight or challenge
- Strong analytical and judgment skills
- Preferred: CAMS, CFE, CRCM, or similar certifications
- Experience with Customer Risk Rating (CRR) or Transaction Monitoring model governance
- Experience leveraging data analytics or reporting tools in QA
- Strong sense of independence and professional skepticism
- Ability to assess quality of judgment and oversight (not just execution)
- Excellent written and verbal communication skills
- Ability to influence and challenge peers within Compliance
- Attention to detail with a focus on consistency and governance
- Strong organizational and problem-solving skills
- Quality and consistency of 2LoD QA reviews
- Identification of meaningful gaps in oversight and challenge
- Reduction in repeat QA findings within 2LoD
- Timeliness and effectiveness of issue remediation
- Positive feedback from regulators and Internal Audit on 2LoD QA program
- Demonstrated improvement in 2LoD governance and decision-making quality
Qualifications
Key Competencies
Success Metrics
Pay
Salary range: $43,000 – $70,000
Benefits
Pathward offers a comprehensive benefits package for eligible employees, including health insurance, 401(k) retirement benefits, life insurance, disability benefits, paid time off, and more.