Compliance Analyst

SUMMARY OF FUNCTIONS :

The Compliance Analyst (CA) is responsible for performing various day-to-day responsibilities including, but not limited to, reviewing new account opening applications and ongoing customer due diligence entries prepared by the Business staff, ensuring compliance with the requirements established by the Bank Secrecy Act, USA PATRIOT Act, and OFAC regulations as well as Agency’s policy.

The CA also performs transaction monitoring and OFAC sanctions screening-related activities.

PRINCIPAL DUTIES :

Ø Review new account opening applications for personal and corporate accounts to ensure compliance with CIP and due diligence requirements, including the Final CDD Rule.

Sign off the new account application process for Moderate and Low risk accounts.

Ø Review and sign-off ongoing customer due diligence updates prepared by the business staff (e.g., CDD follow-up inquiries, beneficial ownership certifications, call and visit reports).

Ø Provide support as an initial reviewer in the performance of periodic due diligence updates for individual customers. Perform the respective transaction analysis.

Ø Conduct all-encompassing due diligence reviews for existing corporate customers, in accordance with the risk-based frequency established by policy, and as directed by the Compliance Officer (CO).

Ø Perform transaction monitoring, including research and disposition of ECS account exceptions (red flag notifications on an alternate basis for daily / weekly flags and monthly deviations from profiles) to ensure that transactions match the expected activity on accounts.

Ø Complete routine maintenance tasks in the ECS monitoring system (e.g., account profile, customer / person / account records) for new customer accounts, due diligence reviews, and KYC follow-ups / updates.

Ø Review and / or sign-off on matching transactions triggered by the OFAC-EDD Verifier’s internal (denial) sources (e.g., MSBs, IVTS, CMC, CPA, Cuba Restricted, Prohibited, Section 311).

Ø Maintain the OFAC Actions Log and validation records pertaining to updates to the OFAC Sanction Lists applied by the vendor.

Ø Assist in the gathering of check supplemental information (drawers and payees) for aggregation in the Compliance Area's monthly transaction analysis databases used for the disposition / completion of activity exceptions and periodic due diligence reviews.

Ø Review and dispose of potential matching CIF records triggered by the OFAC-EDD Verifier following established dual control procedures, as applicable.

Ø Conduct investigative research for unusual or suspicious activity identified through the account monitoring or referral processes, as directed by the Investigation Log Custodian.

Produce case investigative reports maintaining adequate documentation to support SAR / no-SAR determinations.

Ø Assist in the research and production of documentation responsive to subpoenas, warrants, and other special requests as well as Treasury Department’s exceptional orders and national security letters, as directed by the CO or CCO.

Ø Any other duties, as may be assigned by the CO or CCO.

Ø Ensure compliance with BSA / Anti-Money Laundering regulations.

Ø Adhere to Federal and State laws and regulations.

Ø Adhere to Bank / Agency’s policies and procedures.

SECONDARY DUTIES :

Ø Evaluate FATCA system-generated alerts and ensure that due diligence on accounts with U.S. indicia is performed, including gathering appropriate 'cure' documentation or a valid Form W-9 for all identified reportable accounts.

Ø Perform 180-day transaction activity reviews for newly opened high risk rated personal and legal entity accounts, documenting the review outcome and escalating any account behavioral deviations for further review by the Relationship Managers / Account Officer via ECS. (Back-Up)

Ø Review escalated matching transactions triggered by the OFAC-EDD Verifier interdiction software’s internal watch list (Dubai, Singapore, Chaoyang, SOFOM, SAPI). (Secondary Back-Up) .

Ø Review escalated matching transactions triggered by the OFAC-EDD Verifier interdiction software’s published sources (OFAC SDN, Sanctioned Countries, European Union, and United Nations) (Secondary Back-Up) .

Ø Evaluate FATCA system-generated alerts and ensure that due diligence on accounts with U.S. indicia is performed, including gathering appropriate 'cure' documentation or a valid Form W-9 for all identified reportable accounts (Back-up) .

Ø Any other duties, as may be assigned by the CO or CCO.