BANK SECRECY HIGH RISK PORTFOLIO ANALYST

BAYCOAST BANK

POSITION DESCRIPTION

POSITION TITLE: BANK SECRECY HIGH RISK PORTFOLIO ANALYST

DEPARTMENT: RISK MANAGEMENT & COMPLIANCE

LEVEL: 107

Bilingual a plus

FUNCTION:

Under the supervision of the FVP BSA/AML Officer and the Assistant Bank Secrecy Act & Anti-Money Laundering (BSA/AML) Officer performs on-boarding, monitoring and completes appropriate investigations. Conducts reviews of transactions and activities of certain high-risk customers/relationships of the Bank. The analyst will be required to complete due diligence reviews as required under the Bank's procedures and prepare SAR's and CTR's for filing in accordance with regulatory requirements.

JOB DUTIES:

1. Meets with or has conversations with prospective business account holders and sets expectations regarding the requirements of the banking relationship. Acts as the main point of contact for the business. Involved in all aspects of on-boarding and manages the relationship on an on-going basis. Responds to customer inquiries in a timely and professional manner. Develops a comprehensive knowledge of the business and its practices. Ensures that any identified concerns are communicated and addressed with the customer.

1. Assists the Assistant BSA/AML Officer with the monitoring of a subset of the Bank's high-risk portfolio in accordance with regulatory requirements.
   • Verifies with appropriate state authorities that the business is duly licensed and registered;
   • Reviews the license application and related documentation submitted by the business for obtaining a state license to operate its the business;
   • Requests from state licensing bureau and enforcement authorities' available information about the business and related parties;
   • Develops an understanding of the normal and expected activities for the business, including the types of products to be sold and the type of customers to be served;
   • On an ongoing basis monitor publicly, available sources for adverse information about the business and related parties;
   • Ensures all required licenses are current;
   • Prepares and organizes account-opening documentation packages;
   • Obtains and reviews updated documentation on a periodic basis;
   • Makes recommendations to exit the relationship if warranted

1. Organizes and prepares required documentation for on-site visits. Conducts on-site visits as necessary. Ensures reviews are accurately completed in a timely manner or as needed if there is an identified concern.

1. In a timely manner, monitors all account transactions including sales and reporting to ensure activity is normal, consistent, and expected for the business type. Conducts Enhanced Due Diligence if there is a concern or red flag that the business deviates from Bank expectations, the FinCEN guidance or violates state law.
   • Keeps the BSA/AML Officer and/or Chief Risk Officer advised on any potential violations.

1. Assists the Assistant BSA/AML Officer in the set up and completion of Suspicious Activity Reports (SARs), which includes a detailed analysis of the transaction activity, and compiling appropriate supporting documentation and a comprehensive SAR narrative.

1. If needed, prepares and reviews business related Currency Transaction Reports to be filed with the appropriate government agency within the timeframe allowed by regulation. Utilizes the Bank's AML software (Verafin) to track cash activity related to CTR reporting.

1. Monitors assigned cases in Verafin, ensures investigations are conducted in a timely manner, and customer due diligence is performed and documented in accordance with regulatory requirements. When appropriate, recommends and sets custom behaviors in Verafin for customers who's normal and expected activity continually exceeds the system's global parameter settings.

1. Assists the Assistant BSA/AML Officer with the ongoing monitoring of the Bank's compliance with the Office of Foreign Assets Control (OFAC). Duties include performing OFAC checks on incoming and outgoing wire transfers utilizing third-party software (WITS).

1. Assists Deposit Operations, Ecommerce and Finance with the monitoring of ACH and Wire transactions for the high-risk portfolio subset. Utilizes "Salesforce" for review of CRB rejected transactions for approval or denial. Creates additional "Salesforce" cases as need for day-to-day business activity.

1. Assists the Assistant BSA/AML Officer with Verafin's AML and wire alert process; monitors account activity and advises management on any potential concerns. Ensures alerts are cleared and acknowledged in a timely manner.

1. Works closely with Retail Business Development to ensure business needs are met with regards to business online banking, debit card access, etc.

1. On a rotating basis, assists the Assistant BSA/AML Officer with daily customer correspondence to ensure inquiries and issues that arise are completed in a professional and timely manner. Advises management of any potential concerns.

1. Assists the BSA/AML Officer in compiling data, documentation, etc. for various BSA/AML audits (internal, external, or regulatory).

1. Works with new hires to ensure they have proper understanding of the department's policies and procedures. Recommends updates to procedures as necessary.

1. Keeps abreast of developments (i.e., regulatory, technological, etc.) within the banking industry pertaining to the Bank Secrecy Act and anti-money laundering activities. Recommends updates to internal procedures as necessary.

1. Assumes additional responsibilities as requested.

1. Maintains highly confidential information and may be required to perform confidential investigations into suspected activity.

1. Embraces the Bank's commitment to Solutions by seeking and recognizing opportunities to refer new business to different areas of the Bank, BayCoast Financial Services, BayCoast Insurance, Plimoth Investment Advisors, BayCoast Mortgage Company, LLC, and Priority Funding.

1. Embraces the Bank's credo.

KNOWLEDGE, SKILLS & ABILITIES:

• Must be proficient in the Microsoft Office Suite.
• An in-depth knowledge of the Bank Secrecy Act rules and regulations is required.
• Must possess a strong understanding of money laundering and high-risk customers.
• Ability to research and understand state law
• Good verbal and written communication skills
• Basic accounting skills
• Ability to resolve problems and research them.
• Very detailed oriented.

MINIMUM EDUCATION, TRAINING & WORK EXPERIENCE:

• Bachelor's degree in business, Accounting, Criminal Justice or another related field preferred.
• Three to five years of BSA/AML experience required.
• Compliance and/or legal training a plus.
• Working knowledge of BSA/AML automated software.
• Experience with Verafin is preferred but not required.
• ACAMS Certification preferred

EQUIPMENT USED:

General office equipment.

PHYSICAL/WORK CONDITION REQUIREMENTS:

In the performance of respective tasks and duties, the employee is expected to successfully perform the essential functions of the position. Reasonable employee accommodation for physical or mental disabilities will be considered on a case-by-case basis. While performing duties the employee is required to sit, talk, hear, lift up to 20 lbs., and may be required to work evenings and/or weekends, attend remote meetings and/or travel.