Senior Compliance Officer – Enterprise FinCEN Programs Governance SME

The Senior Compliance Officer serves as Financial Crimes Risk Management’s (FCRM) enterprise subject matter expert (SME) and senior second-line compliance authority for technical compliance with and meeting the spirit of FinCEN Programs such as Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs, including Purchase and Sale of Certain Monetary Instruments Recordkeeping aka Monetary Instrument Log [MIL]), Reports of Foreign Bank and Financial Accounts (FBARs), “Special Measures” Pursuant to Section 311 of the USA PATRIOT Act (Special Measures), and “Information Sharing” Pursuant to Section 314(a) and (b) of the USA PATRIOT Act (Information Sharing). 

This role provides enterprise-wide governance, oversight, credible challenge, and strategic guidance to help ensure related processes, procedures, standards, controls, systems, data, and supporting documentation are appropriately designed, implemented, maintained, and operating effectively. The Senior Compliance Officer partners across the first, second, and third lines of defense to identify regulatory risk, assess related control coverage and design, resolve complex matters, drive sustainable remediation, and promote consistent execution across all applicable legal entities, businesses, products, channels, and customer segments.

• →Serve as the enterprise subject matter expert for and to ensure technical compliance with and meeting the spirit of FinCEN Programs including SARs, CTRs / MIL, FBARs, Special Measures, Information Sharing, and related regulatory requirements and industry practices.
• →Execute risk oversight activities in accordance with the FCRM governance framework, related standards, and requirements.
• →Know and provide compliance oversight of technology evolution / transformation, data governance, data lineage / flows, data quality, data dependencies, data access, data platforms, record retention, system functionality, automated decisioning, rules, models, and other technology changes affecting SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing.  Learn and identify the entire cradle-to-grave processes at KeyBank for SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing, including all technology inputs and/or manual processes which could affect outputs, to ensure full compliance with FinCEN Programs.
• →Provide second-line oversight and credible challenge of all enterprise-wide processes, procedures, controls, systems, tools, data, and operational practices and facets supporting FinCEN Programs including SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing.
• →Interpret applicable laws, rules, regulatory guidance, examination expectations, and enforcement themes; assess enterprise impact; and translate requirements into clear policies, standards, control expectations, and implementation guidance.
• →Own and provide authoritative review and approval of enterprise policies and standards for FinCEN Programs including SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing, and oversee the governance of supporting first-line procedures and job aids.
• →Evaluate whether controls are appropriately designed to mitigate inherent and residual risks and whether control execution is effective, consistent, evidenced, and sustainable across the enterprise.
• →Identify gaps, emerging risks, inconsistent practices, control weaknesses, and potential regulatory exposure; communicate the risk clearly; and require timely corrective action or formal risk acceptance, as appropriate.
• →Support enterprise risk assessments, including BSA/AML risk assessments, regulatory compliance risk assessments, risk and control self-assessments, customer risk methodologies, and topical assessments related to SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing.
• →Define and monitor risk appetite, risk tolerance, key risk indicators, key performance indicators, control metrics, quality results, exceptions, backlogs, aging, and other management information used to assess program health.
• →Review and challenge business process risk identification, new or modified products and services, customer journeys, delivery channels, acquisitions, integrations, third-party arrangements, and material changes that may affect SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing obligations.
• →Provide senior compliance guidance and influence on complex, high-risk, novel, or escalated customer matters, including for SARs, CTRs / MIL, FBARs, Special Measures, and Information Sharing.
• →Partner with Legal, BSA/AML leadership, FCRM teams, business compliance, operations, technology, data, model risk, fraud, privacy, third-party risk, Internal Audit, and independent testing teams to promote an integrated and consistent control environment.
• →Oversee, develop, or provide credible challenge to quality assurance, compliance monitoring, independent testing, internal audit, and regulatory examination activities; assess results, identify systemic themes, and track management response.
• →Provide subject matter leadership for regulatory examinations, audits, inquiries, and information requests, including preparation of narratives, evidence, issue responses, and presentations to senior management or governance committees.
• →Oversee issue and finding identification, remediation, severity assessment, root-cause analysis, corrective-action design, validation readiness, risk acceptance, and sustainable closure for SAR, CTR / MIL, FBAR, Special Measures, and Information Sharing matters.
• →Establish enterprise training requirements and provide or oversee targeted training, communications, implementation materials, and subject matter support for affected employees and stakeholders, in accordance with the FCRM Governance Framework standards and requirements
• →Prepare and present concise reporting on risk exposure, program effectiveness, control performance, significant issues, emerging risks, and remediation status to senior management, governance committees, and the Board, as appropriate.
• →Lead cross-functional initiatives and working groups, mentor compliance professionals, and promote consistent interpretation and application of enterprise requirements without direct supervisory responsibility.
• →Maintain current knowledge of regulatory developments, enforcement actions, peer practices, and evolving financial crime risks, and recommend enhancements to the enterprise compliance program.

• Acts as the senior compliance escalation point for interpretation and application of enterprise SAR, CTR / MIL, FBAR, Special Measures, and Information Sharing requirements.
• Provides independent credible challenge and documents material concerns, required actions, and risk-based recommendations.
• Recommends approval, conditional approval, escalation, remediation, restriction, or decline when compliance requirements or risk appetite are not met. Maintains required documentation in accordance with the FCRM Governance Framework Standards and requirements.
• Escalates material regulatory risk, control breakdowns, overdue remediation, or unresolved disagreements through established governance channels.
• Is accountable for the quality, consistency, and timeliness of second-line guidance, influence, and oversight within the assigned subject matter domain.

• Bachelor’s degree or equivalent combination of education and relevant experience.
• Extensive experience in BSA/AML, financial crimes compliance, regulatory compliance, risk management, Legal, Internal Audit, or a related discipline within a financial institution or regulatory environment, specifically in the areas of SAR / CTR / MIL / FBAR / Special Measures / Information Sharing operations.
• Deep knowledge of SAR, CTR / MIL, FBAR, Special Measures, Information Sharing, and risk-based compliance program regulations and regulatory expectations.
• Demonstrated ability to interpret regulatory requirements and translate them into enterprise policies, standards, controls, governance routines, and practical business guidance.
• Experience evaluating complex processes and control environments (including the technology involved), identifying systemic risk, and influencing sustainable corrective action.
• Strong executive communication, facilitation, negotiation, and written documentation skills, with the ability to explain complex risk matters clearly and concisely.
• Demonstrated ability to lead cross-functional initiatives, influence senior stakeholders, and provide credible challenge in a complex, highly regulated environment.

• Advanced degree in law, business, finance, risk management, criminal justice, or a related field.
• Professional certification such as CAMS, CFE, CRCM, CFCS, or a comparable compliance or financial crimes credential.
• Experience with large or complex financial institutions, multiple lines of business, enterprise transformation, regulatory remediation, or direct regulatory examination engagement / oversight.
• Knowledge of data governance, model risk management, technology controls, automation, and systems supporting customer onboarding and lifecycle management.

• Enterprise risk leadership, strategic judgment, and influence
• Regulatory interpretation and policy governance
• Independent oversight and credible challenge
• Control design and operating-effectiveness assessment
• Issue management and sustainable remediation
• Data-driven risk analysis and management reporting
• Executive presence and stakeholder influence
• Cross-functional leadership and change management
• Clear, concise, and defensible documentation
• All KeyBank employees are expected to demonstrate Key’s Values and abide by Key’s Code of Conduct.

• Enterprise SAR, CTR / MIL, FBAR, Special Measures, and Information Sharing requirements are current, clear, consistently governed, and aligned with regulatory expectations and risk appetite.
• Material risks, control weaknesses, and emerging issues are identified early, escalated appropriately, and remediated sustainably.
• Processes, procedures, controls, systems, data, and documentation demonstrate effective and consistent execution across applicable businesses and legal entities.
• Senior management and governance committees receive accurate, timely, useful decision reporting and advice.

• General Office - Prolonged sitting, ability to communicate face to face in person or on the phone with teammates and clients, frequent use of PC/laptop, occasional lifting/pushing/pulling of backpacks, computer bags up to 10 lbs.

• Preferred location(s): Cleveland or Buffalo (Hybrid in office - 3+ days)

COMPENSATION AND BENEFITS

Please click here for a list of benefits for which this position is eligible.

Key has implemented an approach to employee workspaces which prioritizes in-office presence, while providing flexible options in circumstances where roles can be performed effectively in a mobile environment.

Qualified individuals with disabilities or disabled veterans who are unable or limited in their ability to apply on this site may request reasonable accommodations by emailing HR_Compliance@keybank.com.