Manager, Complex Investigations Unit, BSA/AML & Sanctions Operations

About the Role:

The Manager, Complex Investigations Unit leads a team of investigators responsible for the review, investigation, and resolution of complex and high-risk financial crime matters across AML, Sanctions, and Fraud domains. The role bridges investigative execution and program ownership: the Manager applies the escalation, quality, and documentation frameworks established by the VP, Complex Investigations, and ensures those standards are executed consistently by the Analysts performing the casework. The Manager serves as the day-to-day escalation point for multi-account, multi-entity, and cross-product matters, reviews and challenges SAR decisioning and narratives before final disposition, manages workload assignment and capacity, and develops investigator capability through coaching, calibration, and targeted training. The Manager is accountable for the quality, timeliness, and defensibility of the unit's investigative outputs under OCC, FinCEN, and internal program standards, and escalates novel typologies, systemic issues, and emerging risks to the VP, Complex Investigations.

What You Will Do:

• Complex Investigations & Escalation Management

  • Manage the intake, assignment, and resolution of complex and high-risk investigations across products and customer types, including multi-account, multi-entity, and cross-product matters.
  • Serve as the day-to-day escalation point for urgent or high-severity matters, elevating to the VP, Complex Investigations where senior leadership awareness or immediate action is required.
  • Apply and enforce established escalation and routing criteria, including handling of repeat SAR subjects, continuing activity, and examiner-, audit-, or enforcement-referred matters.
  • Ensure appropriate identification of subjects, activity scope, and risk exposure across the unit's caseload.
  • Identify emerging typologies, thematic issues, and potential control gaps surfaced through casework and escalate with supporting analysis and recommendations.

  People Leadership & Team Management

  • Directly manage a team of Complex Investigations Analysts; assign work, manage capacity and coverage, and balance inventory against aging and regulatory timeliness requirements.
  • Partner with People & Culture on hiring and staffing for the unit, including requisitions, interviews, and selection.
  • Set performance expectations, conduct 1:1s and performance reviews, and deliver coaching and development plans; address performance issues with timely documentation and escalation.
  • Build team capability through structured onboarding, ongoing coaching, and targeted training on typologies, investigative methods, and narrative quality.
  • Promote a strong control culture, accountability, and adherence to procedures, desktop procedures, and checklists.

  Investigative Oversight, SAR Quality & Documentation

  • Review and challenge investigative analyses, conclusions, and SAR/no-SAR determinations to confirm they are sound, defensible, and fully documented.
  • Ensure SAR narratives, Continuing Activity Reports (CARs), and decisioning meet regulatory expectations and withstand examiner, audit, and law enforcement scrutiny.
  • Confirm investigative documentation meets the five-element documentation baseline and internal quality standards prior to filing or closure.
  • Oversee the unit's response to QC/QA feedback; drive remediation of identified defects and calibrate standards across analysts to reduce repeat findings.
  • Support 314(a)/314(b), OFAC, and PEP-related investigative activity assigned to the unit.

  Program Execution, Governance & Reporting

  • Execute the investigative standards, methodologies, and governance frameworks owned by the VP, Complex Investigations, and provide feedback to strengthen them.
  • Monitor and report unit-level metrics, including inventory, aging, timeliness, SAR volumes, and quality results, to BSA/AML leadership.
  • Support root cause analysis and remediation activities tied to investigations, escalations, audit findings, and MRAs.
  • Maintain examiner-ready case artifacts and contribute to procedure, desktop procedure, and checklist updates as processes evolve.

  Cross-Functional Collaboration & Regulatory Support

  • Partner with Sanctions Operations, Fraud Operations, Compliance Advisory, Legal, and Technology on cross-domain and sensitive high-risk matters.
  • Support regulatory examinations, internal audit, and model/program validation efforts by preparing case artifacts and coordinating responses to information requests.
  Provide investigative support and coaching to product-aligned SAM, Fraud, and Sanctions teams to drive consistency across the enterprise.

What You Will Need:

• Bachelor's degree required (Finance, Criminal Justice, Accounting, Business, or related field).
• CAMS or equivalent AML certification strongly preferred.
• 7+ years of BSA/AML, Sanctions, or Fraud investigations experience, including SAR decisioning and filing.
• 2+ years of direct people management experience, including coaching, performance management, and talent development.
• Demonstrated experience managing complex, high-risk typologies and multi-account or multi-entity investigations.
• Working knowledge of transaction monitoring systems (e.g., Actimize, FCRM) and watchlist/screening tools (e.g., Bridger).
• Demonstrated success defending investigative decisions in audit, exam, or regulatory settings.
• Strong writing and communication skills, including the ability to review and elevate SAR narrative quality and to present results to senior leadership.

Products & Services Knowledge

SAR narratives and investigative conclusions must accurately describe how funds move through each Pathward product, and the unit reviews activity across the full estate. The Manager must hold product-level knowledge of the funds flows, typologies, and party designations across the Bank's seven product categories and its program-manager model, including:

• Card Issuing / Prepaid — GPR, payroll, corporate disbursement, gift, government-benefit and student cards, and the load/spend typologies (structuring, funnel accounts, bust-out) that drive SAR narratives.
• Tax Products (EPS Financial / Refund Advantage) — refund transfers, taxpayer advances (including Emerald Advance®), and tax-office loans, and the IRS/ERO funds flows behind seasonal SAR/CTR volume.
• Acquiring (Merchant & ATM) — merchant/ISO/payment-facilitator activity, transaction laundering, and ATM cash-access typologies.
• Digital Payments & Faster Payments (Visa Direct / Mastercard Send) — push/pull disbursements, P2P, and cross-border rails.
• Consumer Lending, Commercial Finance, and Commercial Deposits — the CTR, continuing-activity, and 314(a) obligations Pathward retains as lender/bank of record and depository institution.

The Bank-vs-Program-Manager framework — Pathward files all SARs, CTRs, and 314(a) responses, so the Manager and their team must trace activity back through the program-manager escalation model.

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

Salary range:  $72,000 – $120,000

 
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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