BSA/AML Compliance Officer

About OliBank

OliBank's mission is to make managing finances as easy as possible. Our vision is an evenly distributed, global, digital-first financial system that levels the playing field.

Our values: Sense of Urgency, Customer Obsession, Pride in Craftsmanship.

How we work: •Culture eats strategy — everyone owns it, everyone can be held accountable to it. •Culture of ownership — keep the bar high, own decisions, correct and learn. •Long-term results over short-term wins — with urgency. •Build great systems, make the complex simple, use forcing functions. •Obsess over the details (culture, customers, product, process, data). •Bias for action, be bold, disagree-and-commit, end with the positive — and mistakes have consequences. There is always room for improvement.

Compliance at OliBank is not a back office. It is how we earn the right to move money globally. This role owns that.

The role Designated BSA/AML Officer. You own a risk-based BSA/AML/OFAC compliance program that satisfies FinCEN, OFAC, and OCIF expectations for a FinCEN-registered MSB operating with a Puerto Rico IFE — including SAR decisioning authority, FinCEN 314(a) handling, sanctions screening governance, and Board reporting.

Main responsibilities

BSA/AML program ownership •Own and maintain the risk-based BSA/AML compliance program (CIP/KYB/KYC, beneficial ownership, EDD, ongoing monitoring, recordkeeping) across the MSB and bank programs, with clear capacity-split documentation for each decision. •Serve as designated BSA Officer with authority for SAR determinations, SAR filing clocks (31 CFR 1020.320), continuing-activity reviews, confidentiality/no-tipping, and 314(a) searches (14-day window, no-hit logs, no disclosure to subjects). •Report directly to the Board on program health, trends, and deficiencies — trends and metrics, never case-file detail in minutes. Sanctions & screening •Govern sanctions screening: direct OFAC SLS ingestion/reconciliation, ITA CSL / EU / UK sources, OFAC 50 Percent Rule ownership handling, pre-submission beneficiary screening, fuzzy-match disposition, and fail-closed behavior on screening outages. •Own OFAC block/reject handling (31 CFR 501.603/601.604, 10-business-day reporting) — confirmed matches block; auto-return/retry only after false-positive disposition. Client lifecycle & transactions •Evaluate onboarding, EDD triggers (high-risk jurisdiction, complex ownership, volume, PEP/sanctions), and transaction activity for compliance risk. •Proactively audit processes, KYB artifacts, monitoring alerts, and CIS risk-scoring dispositions; document findings, remediations, and residual risk. •Own vendor and counterparty compliance touchpoints: compliance sign-off on vendor reviews where BSA/AML screening or monitoring is implicated.

Controls, training, culture •Build simple, systemic internal controls with forcing functions — not one-off customizations. No "100% guarantee" language; design for reasonable, risk-based, auditable compliance. •Own the training program (staff, engineering/CIS, Board orientation, alternate/interim BSA coverage). •Manage independent testing / audit remediation, examiner requests (OCIF, IRS BSA exam for MSB), and the residual-risk register.

Experience required •3+ years BSA/AML compliance experience in a regulated financial institution; direct experience with a Puerto Rico IFE / OCIF examination cycle required. •Hands-on SAR lifecycle: investigation, determination memos, filing clocks, continuing activity, confidentiality. Must be able to evidence SAR decisioning authority. •Working knowledge of BSA recordkeeping, funds-transfer recordkeeping (§1010.410), FinCEN 314(a), OFAC administration, and MSB obligations (31 CFR Part 1022 vs. bank Part 1020/CIP differences). •Experience with transaction monitoring / risk-scoring systems, KYB/KYC vendors, and audit of alert dispositions (false-positive rationale discipline). •Risk management and/or financial-crimes audit experience (2+ years). •Strong research, writing, and Board-level communication skills. Fluent English required; Spanish a strong plus (OCIF/market reality). •Integrity, independence of judgment, and willingness to veto — disagree-and-commit cuts both ways; the BSA decision is yours. Strongly preferred •Professional certification: CAMS, CGSS, CRCM, or equivalent. •Stablecoin / cross-border payments experience. •Data-protection literacy (GDPR concepts); privacy-framework experience is a plus, not core.

Education •University degree in law, finance, business administration, or related field. JD or advanced degree a plus, not required.

Location: Must be located in or self-relocating to Puerto Rico

 

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