Director of BSA & AML Financial Crimes Operations

About the Team/Role 

Job Summary

WEX Inc., located in Portland, ME is seeking a self-driven and experienced Anti-Money Laundering (AML) and Countering the Financing of Terrorist (CFT), formerly Bank Secrecy Act (BSA), professional to join the WEX Inc. Anti-Financial Crimes team. Reporting to the WEX Inc. VP, Anti-Financial Crimes, this individual is responsible for the U.S. AML/CFT regulatory operations center of excellence for WEX Inc., and its subsidiaries, including and especially WEX Bank, an industrial bank located in Sandy, UT. This position will have a dotted line to the WEX Bank, Chief Compliance Officer.

How you'll make an impact

The ideal candidate will have the opportunity to perform, among other things, the following:

Develop and Manage Efficient, Risk-Based, and Compliant BSA and AML Program

• Design and execute the global strategy for WEX's Anti-Money Laundering (AML)/Know Your Customer (KYC) programs associated with the onboarding and monitoring of clients for regulated businesses, as well as the enhancement of the of global economic sanctions screening and analysis program

• Manage Bank Secrecy Act, USA Patriot Act (314a/b), Anti-Money Laundering and Know Your Customer programs including monitoring and escalations, to meet regulatory and business requirements

• Establish strategy for selection and submission of suspicious activity reports (SARs), including initial and continuing activity SARs, as warranted.

• Establish a methodology and operational approach to monitor and report ongoing activity.

• Create a consistent process with adequate documentation for No-SAR decisions.

• Prepare and present reports on suspicious activity, SARs filed, No-SAR decisions, and other financial crime trends.

• Manage or participate in the management of controls implemented in various areas of the business that assist in the identification and referral of potentially suspicious activity (e.g., internal lines of business, risk management,  third parties with whom AML/CFT functions have been outsourced, treasury/finance, information security/information technology, cyber security, human resources, sales, etc.)

• Manage the high risk customer identification and (annual+) EDD review process for customers deemed to be high risk.

• Manage sanctions, OFAC, and other watchlist screening activities, including the review of This potential alerts, clearing of alerts, documenting false positives, escalating potential matches, and preparing documentation for reporting of actual matches.

• Assisting with risk assessments and regulatory examinations where needed

• Provide strategic direction for WEX’s client and counterparty onboarding services, including defining and setting processes and procedures, implementing metrics and tools to manage capacity, embed service level commitments and drive enhancements to simplify and streamline processes to enhance the client experience.

• Create, develop, and maintain the business requirements for AML/CFT/Sanctions-related technology solutions; participate in any RFP or similar process for vendor selection; participate in and oversee development and implementation of said technology; conduct initial and periodic (e.g., annual) reviews/tests on settings, assumptions, and other systemic parameters to ensure they remain appropriate and effective and support the WEX Inc. and WEX Bank’s risk management objectives; submit any algorithms, models, AI, or other technology tools through the appropriate governance review (e.g., model risk management).

• Monitor and communicate potential changes in applicable financial crime regulations and providing advice to the business regarding any such development, including working with outside counsel and other experts to advise the company on its financial crime compliance obligations 

• Other duties, as assigned. 

Lead a Fraud Governance & Compliance Center of Excellence Program

• Own and execute the Fraud Risk Management Committee (FRMC) function, including coordinating content, presenters, and leading meetings.

• Maintain the Global Fraud Risk Assessment (FRA), produce annual reports, update and manage the risk register, provide support for project prioritization, and deliver appropriate reporting of risks and mitigations.

• Maintain an up-to-date access and application inventory for all Lines of Business (LOBs) globally, maintain control inventories for portals, and an inventory of BINs and associated control inventories. Work with IAM leadership to develop and track action plans to close gaps.

• Track and manage new product development and provide robust risk assessments, track progress and deployment plans, manage gaps in controls, and communicate risks to appropriate Fraud leadership.

• Develop and deploy strategies to inform and educate both internal and external partners on fraud trends, ways to prevent fraud, and advise on controls to improve fraud protections.

• Align embedded compliance and fraud resources to evaluate, consult, and track new and developing products.

• Lead and execute a monthly compliance committee, including initial development, charter, and framework.

• Assist with risk assessments and regulatory examinations where needed.

• Support WEX Compliance functions including complaint management, issue management, non-bank compliance operations and compliance consulting for new products and initiatives.

• Lead a team of embedded risk managers aligned to business units

Create, Provide, and Present Reports to Governance Committees and Executives

• Report and present within a governance framework on WEX Inc.’s compliance with service level agreements (SLAs) with WEX Bank, a SAR-review committee, and third party oversight.

• Support the Bank in all audits, regulatory examinations, and/or requests for information.

• Be a subject matter expert (SME) on regulatory guidance, FinCEN guidance, FILs, etc. associated with the roles and responsibilities of this position. Provide proactive information to governance committees and appropriate executive team members on proposed regulatory guidance and the impact it may have on WEX.

• Liaise with global AML/CFT SMEs.

Lead a High Performing Team

• Manage a global team of experts who are responsible for the various AML/CFT/Sanctions operational process work, ensuring compliance with policies, procedures, and SLAs.

• Manage any third parties providing contract or other temporary workers to ensure that work performed by third parties meets the standards of quality and excellence required by WEX.

• Create and maintain a current and accurate new employee/new hire/employee transfer onboarding and training program, which includes regulatory requirements, WEX Inc. and WEX Bank policy requirements, and specific, on-the-job training on the functions for which the individual is responsible.

• Encourage and provide opportunities for staff to obtain and/or maintain relevant industry certifications, such as Certified Fraud Examiner, Certified Anti-Money Laundering Specialist, etc.

• Educate and train internal staff on policy changes, new directives and spotting potential red flags or suspicious activity

Demonstrate Sound Decision-Making Skills and Accountability

• Exercise sound judgment and decision-making skills, including risk-based decisions, especially in times of uncertainty or guidelines are broad. Identify and select complex choices of action where standard practices may not exist.

• Accommodate detailed work, problem solving, reasoning, math, presentations, verbal communication, written communication, analytical reasoning, training others, multiple concurrent tasks and constant interruptions.

Experience you'll bring 

• Bachelor’s degree or equivalent banking experience; advanced degree preferred.

• 12-15 years experience in AML/CFT (BSA) compliance and operations, including leading of teams. At least half of these years must be in U.S. banking with a strong emphasis on AML/CFT compliance. Other experience in payments,  fintech, and other financial services is welcome. Preferred experience in commercial lending, commercial banking AML/CFT. Strongly preferred experience in commercial/business credit card lending and business-to-business (B2B) payments.

• 3-5 Years of experience leading a global team 

• Experience with regulators, managing examinations, and/or reporting to external regulators and auditors.

• Previous experience building and managing BSA & AML programs, and experience with MSBs and third party payment processors (TPPPs).

• Experience managing multiple teams and delivering results across disciplines

• Comprehensive understanding of general banking compliance regulations and laws.

• Comprehensive understanding of general banking operations activities, products, and services.

• Ability to resolve issues, work independently, and meet deadlines.

• Persuasive and team-oriented.

• Ability to communicate effectively with staff at all levels.

• Superior and effective verbal, written, and interpersonal communication skills with the ability to instruct others, train personnel, write reports, correspondence and procedures, and speak clearly to customers and employees.

• Good organizational and time management skills.

• Must pass a successful background investigation.

The base pay range represents the anticipated low and high end of the pay range for this position. Actual pay rates will vary and will be based on various factors, such as your qualifications, skills, competencies, and proficiency for the role. Base pay is one component of WEX's total compensation package. Most sales positions are eligible for commission under the terms of an applicable plan. Non-sales roles are typically eligible for a quarterly or annual bonus based on their role and applicable plan. WEX's comprehensive and market competitive benefits are designed to support your personal and professional well-being. Benefits include health, dental and vision insurances, retirement savings plan, paid time off, health savings account, flexible spending accounts, life insurance, disability insurance, tuition reimbursement, and more. For more information, check out the "About Us" section.Pay Range: $158,000.00 - $210,000.00