Director, BSA High Risk Customer Review

About the Role:

The Director of BSA High Risk Customer Review leads the team responsible for performing customer due diligence (CDD)/enhanced due diligence (EDD) (“high risk”) reviews on the Bank's higher-risk customers across all business lines. This role ensures that high risk customer relationships are thoroughly assessed, appropriately documented, and continuously monitored in accordance with BSA/AML regulatory requirements and the Bank's risk appetite.

The Director is responsible for building and developing a team capable of executing complex customer reviews spanning retail banking, commercial lending, prepaid/issuing programs, and Banking-as-a-Service (BaaS) partnerships. Beyond day-to-day review execution, this role is expected to establish and refine the processes, procedures, and quality standards that govern the high risk review function, ensuring consistency, scalability, and regulatory defensibility as the Bank continues to grow.

What You Will Do:

High Risk Customer Review Program

• Lead the execution of due diligence reviews for high risk customers across all business lines, including retail banking, commercial lending, prepaid/issuing programs, and BaaS partnerships
• Develop and maintain standardized review procedures, templates, quality standards, and escalation protocols that ensure consistency and regulatory defensibility across business lines
• Monitor review volumes, aging, and completion metrics to ensure program expectations are met and identify capacity needs proactively

Process Development & Cross-Business Line Coordination

• Design and build the operational framework for the high risk review function, including workflows, case management standards, documentation requirements, and quality assurance processes
• Identify opportunities to improve review efficiency and effectiveness through process refinement, automation, and better use of available tools and data sources
• Partner with business line leaders, customer onboarding teams, and transaction monitoring and investigations teams to ensure high risk reviews reflect relevant business context and compliance findings
• Stay current on regulatory guidance, enforcement actions, and industry best practices and incorporate relevant developments into the program

Team Leadership & Development

• Build, lead, and develop a team of high risk review analysts and specialists with clear performance expectations, quality benchmarks, and professional development paths
• Provide coaching, mentoring, and ongoing training to build team competency across the Bank's business lines, with particular emphasis on BaaS, issuing, and lending risk reviews
• Manage hiring, onboarding, and succession planning to maintain adequate staffing and capability

Regulatory & Stakeholder Engagement

• Represent the high risk review function during regulatory examinations, internal audits, and external assessments
• Prepare reporting for senior leadership on review activity, trends, and program health
• Partner with other BSA Department stakeholder groups to ensure alignment with the Bank's broader BSA/AML compliance framework, customer risk rating methodology, and suspicious activity monitoring processes

What You Will Need:

• Bachelor's degree required
• Advanced degree (JD, MBA, or master’s in a related field) preferred.
• CAMS, CFCS, or similar certification preferred
• 10+ years of experience in BSA/AML compliance, with significant focus on enhanced due diligence, high risk customer management, or customer risk review programs
• At least 5 years of experience directly leading teams of eight or more compliance professionals
• Demonstrated experience developing and operationalizing review processes, procedures, and quality assurance frameworks in a regulated financial services environment
• Strong understanding of BSA/AML regulatory requirements including CDD/EDD, beneficial ownership, customer risk rating, and suspicious activity reporting
• Working knowledge of risk characteristics across multiple banking business lines
• Proven ability to manage review volumes, team capacity, and program metrics in a high-throughput environment

Preferred Experience

• Direct experience operating in a similar role within the BaaS space, with knowledge of the unique compliance challenges associated with partner bank models, fintech relationships, and program management
• Experience with prepaid card issuing programs and the associated customer and transaction risk considerations
• Experience with lending-related customer due diligence, including understanding of loan product risk characteristics and borrower review requirements
• Experience leading program transformation

Competencies

• Strong analytical and investigative mindset with the ability to assess complex customer relationships and identify risk indicators
• Process-oriented with a track record of building scalable, repeatable compliance workflows
• Effective people leader with experience developing teams across a range of experience levels and subject matter areas
• Excellent written and verbal communication, including the ability to articulate risk findings clearly to senior leadership and regulators
• Adaptability and sound judgment in navigating evolving regulatory expectations and emerging risk typologies across diverse business lines

The responsibilities listed above are not all inclusive and may be changed at any time.

Salary range: $86,000 – $145,000

 
The salary range reflects the minimum and maximum target for a new hire in this role. Individual pay within the range will be determined by multiple factors which can include but are not limited to a candidate’s experience, qualifications, skills, and location. Your recruiter can share more about the specific salary for your location during the hiring process. Ranges may be modified in the future.
This role is also eligible for an annual performance-based incentive opportunity.  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.

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