Financial Crimes Risk Manager (High Risk Customers and Accounts, Monitoring, Surveillance, and Reporting)

Function: High Risk Customers and Accounts, Monitoring, Surveillance, and Reporting

Summary: The Financial Crimes Risk Manager will manage and ensure the bank's compliance with the assessment of financial risk of customer's, ensuring the Bank's compliance with the applicable aspects of the Bank Secrecy Act (BSA), USA PATRIOT Act, and Office of Foreign Assets Control (OFAC) regulations by monitoring, identifying, reporting, and investigating suspicious activity relative to potential money laundering activity, financial crimes and/or terrorist financing. Oversee High Risk Customer and Account reviews and investigations in support of the bank's compliance with Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations, the Office of Financial Asset Control by performing the following duties and to mentor other analyst performing similar tasks.

Duties and Responsibilities include the following:

* Develops and manages high risk identification, monitoring, and reporting procedures to ensure effectiveness and compliance with banking regulations. Makes improvements to policies and procedures to maximize departmental resources.

* Oversees the development of curriculum and training plans for employees on the Financial Crimes Risk Management (FCRM) High Risk Customer/Account Monitoring Team.

* Supervises the assigned FCRM Analysts' production through review of work, allocating resources, setting priorities and progressing team members' technical skills and knowledge.

* Oversees scheduled Enhanced Due Diligence (EDD) reviews of accounts deemed as high risk, including but not limited to Money Service Businesses (MSBs), Marijuana/Cannabis-related Businesses (including those adjacent to this industry), Non-Bank Financial Institutions (NBFIs), Politically Exposed Persons (PSPs), Non-Resident Alien (NRA), Privately-Owned ATM Operators (POATMs), Crypto-Currency, etc.; documents EDD monitoring and tags accounts appropriately in Verafin.

* Reviews reports in Verafin to determine if there are Non-Government Organizations (NGOs) Marijuana Related Businesses, or Money Services Businesses unidentified in the financial crimes surveillance system. Adds tags and comments as needed.
* In conjunction with the Director of Financial Crimes Risk Management, implements legislative and regulatory requirements related to the BSA and other anti-money laundering.
* Prepares for and coordinates regulatory and audit compliance examinations as it relates to High Risk Customer and Account processes and procedures.
* Conducts due diligence research/investigations on potentially high-risk new and existing customers. Ensure ongoing due diligence efforts are maintained while identifying substantive changes to customer information or status.
* Instructs direct reports on searches utilizing Internet sources and/or third-party vendors to determine negative news and obtain due diligence information for prospects and new/existing customers.
* Communicates effectively with peers, front-line and management when requesting information or documentation and addressing concerns or findings.
* Adheres to all designated time frames, manage workflow to the specified deadlines and complete responsibilities in a satisfactory manner.
* Thoroughly documents findings by preparing management reports in a manner that is clear and comprehensible to the Director of Financial Crimes Risk Management, internal auditors and regulatory examiners.
* Completes all job-related training in a timely manner and attend seminars or continuing education, as directed.
* Performs any other assignments as directed by the Director of Financial Crimes Risk Management.
* Conducts regular team meetings with direct reports ensuring the lines of communication are open to all individuals on the team regardless of location.
* Takes accountability for all High Risk Customer and Account related functions and processes, procedures, and risk assessments.
* Accurately analyzes transactional account trends and patterns, identification documentation to efficiently document a conclusion upon completion of Ongoing DD reviews of high-risk customers. Makes decision to keep high risk, reduce to medium risk or refer for account closure.
* Provides updated information to the Director of Financial Crimes Risk Management for revising procedures for the handling of newly identified high-risk customers, to include the proper method to review such accounts and to report suspicious activity, document relationships and/or recommendation of account closure if deemed necessary.
* Evaluates transactional activity in accounts identified as PATM or MSB to determine any unusual patterns or lack of cash activity based on trends.
* Stays up-to-date on MSB/MRB requirements for Louisiana, Mississippi and Texas, Alabama, and Florida as well as federal guidelines.
* Communicates with applicable bank personnel to obtain any further documentation and/or information necessary to complete the investigations or reviews of high-risk accounts.
* Tracks documentation required on all MSBs and directly works with Retail and Lending employees to resolve any exceptions.
* May be assigned alerts in Verafin for Red Flags or New Account scenarios and others as assigned to review and determine if the alert can be cleared or needs further investigation.
* Utilizes a variety of internal bank systems and external research tools to investigate, research, and prepare documentation related to anti-money laundering investigations.
* Develops an understanding of the industry and AML related regulations, as well as patterns of behavior that represent suspicious activity.
* Stays up-to-date on current and new policies and regulations as they relate to anti-money laundering schemes and characteristics.
* Supports any special projects or critical casework regarding BSA/AML matters.

Supervisory Responsibilities
Directly supervises a team of Financial Crimes Risk Analysts. Carries out supervisory responsibilities in accordance with the organization's policies and applicable laws. Responsibilities may include training employees; planning, assigning, and directing work; appraising performance in conjunction with other BSA management; addressing complaints and resolving problems.

Competencies - To perform the job successfully, an individual should demonstrate the following competencies:

Analytical and Design - Strong problem solving and analytical skills required to succeed in this job; Strong technical troubleshooting skills and ability to juggle simultaneous complex projects.

Problem Solving - Identifies and resolves problems in a timely manner; Gathers and analyzes information skillfully; Works well in-group problem solving situations; Uses reason even when dealing with emotional or confidential topics.

Interpersonal Skills/Customer Service - Maintains confidentiality; Remains open to others' ideas and tries new things; Responds to requests for service and assistance; Meets commitments.

Oral and Written Communication - Speaks clearly and persuasively in positive or negative situations; Listens and gets clarification; Responds well to questions; Able to read and interpret written information.

Teamwork - Balances team and individual responsibilities; Contributes to building a positive team spirit; Puts success of team above own interests; Supports everyone's efforts to succeed.

Organizational Support - Follows policies and procedures; Completes administrative tasks correctly and on time; supports organization's goals and values.

Judgment and Motivation - Exhibits sound and accurate judgment; Supports and explains reasoning for decisions; Includes appropriate people in decision-making process; Makes timely decisions.

Planning/Organizing - Prioritizes and plans work activities; Uses time efficiently.

Professionalism - Approaches others in a tactful manner; Reacts well under pressure; Treats others with respect and consideration regardless of their status or position.

Quality and Quantity - Demonstrates accuracy and thoroughness; Completes work in timely manner.

Adaptability - Adapts to changes in the work environment; Manages competing demands; Able to deal with frequent change, delays, or unexpected events.

Attendance/Punctuality and Dependability - Is consistently at work and on time; Ensures work responsibilities are covered when absent; Follows instructions, responds to management direction; Takes responsibility for own actions; Commits to long hours of work when necessary to reach goals.

Qualifications
To perform this job successfully, an individual must be able to perform each essential duty satisfactorily. The requirements listed below are representative of the knowledge, skill, and/or ability required. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.

Education and/or Experience
Bachelor's degree from four-year college or university required; minimum seven (7) years in banking or equivalent combination of education and experience. Prior Financial Crimes/BSA/AML management experience, preferably in EDD, KYC/CDD, and beneficial ownership and retail banking experience required. Prior experience with case management systems (Verafin experience preferred), databases, and similar automation. Association of Certified Anti-Money Laundering Specialists (ACAMS), Certified Fraud Examiner (CFE), or similar compliance certification required. Prior BSA-related officer, examiner, or audit experience will be considered in lieu of college degree or certification. If not certified, must be willing to become certified within one (1) year of hire.

Computer Skills
To perform this job successfully, an individual should have knowledge of the Internet, Outlook, Microsoft Word and Excel. Ability to learn bank-specific software such as MPC, IBS, ADP, etc. Ability to use basic office machines.

Other Skills
Maintains proficient knowledge of the rules and regulations, including but not limited to, the Bank Secrecy Act, USA Patriot Act, and OFAC as well as the bank's policies and procedures.
Understands how to operate all systems and software programs used to obtain customer information, transaction history, and archive reports used to gather information for the BSA program.

Bank Culture/Customer Service Skills
Ability and judgment to interact and communicate appropriately with other employees, customers and supervisor. Ability to serve customers, both internal and external, (community/public) in a manner that will reflect superior customer relations and enhance the overall marketing effort of Origin Bank.

Physical Demands
While performing the duties of this job, the employee is frequently required to stand; walk; sit; use hands to finger, handle, or feel and talk or hear. The employee is occasionally required to reach with hands and arms; climb or balance and stoop, kneel, crouch, or crawl. The employee must frequently lift and/or move up to 10 pounds and occasionally lift and/or move up to 25 pounds. Specific vision abilities required by this job include close vision, distance vision and ability to adjust focus.

Work Environment
The noise level in the work environment is usually moderate.

Location
Generally, within retail branch and operations footprint. Hybrid or Remote work may be available at the Bank's discretion. Travel to and from markets where Financial Crimes Risk Management (FCRM) High Risk Customer/Account Monitoring Team members work will be required periodically (generally once a month).

This job description reflects management's assignment of essential functions. It does not prescribe or restrict the tasks that may be assigned. Origin Bank shall, in its discretion, modify or adjust the position to meet the Bank's changing needs. This job description is not a contract and may be adjusted as deemed appropriate in the Bank's sole discretion.

Origin Bank is an equal opportunity employer and we do not discriminate in hiring or employment on the basis of race, color, sex, age, marital or veteran status, non-job related disability, religion, national origin, genetic information or any other basis protected by law.

Remote positions are intended to be filled in states within our footprint, which includes: Alabama, Florida, Louisiana, Mississippi, and Texas. Any exception to this policy requires further regulatory review and approval by management.