Position Title
CRB Risk Specialist
Location
Headquarters-Troy, MI
Job Summary
The Financial Crimes Unit is part of Flagstar Bank’s (the “Bank”) second line of defense in the Bank’s quest to provide an effective BSA/AML compliance program. As part of its fight against money laundering and terrorist financing, the Bank Secrecy Act (BSA) requires financial institutions to apply more stringent controls to reduce the risks of money laundering and terrorist financing which are presented by higher risk customers. Customers who pose higher money laundering or terrorist financing risks present increased exposure to financial institutions; therefore, higher risk customers and their transactions should be reviewed even more closely at account opening and more frequently throughout their account relationship. The Bank’s Cannabis Related Business (CRB) Risk Management Program allows CRBs to have access to the financial system in a selective, secure, and closely monitored environment. Due to their business type and cash intensive business (CIB) nature, CRBs are considered among the Bank’s highest risk customers. The CRB Risk Specialist is responsible for supporting the productivity, quality, and overall performance of the CRB team. In this position, an effective CRB Risk Specialist will be able to assist the BSA/AML Risk Manager in implementing a comprehensive CRB program. The CRB program will adhere to Financial Crimes Enforcement Network (“FinCEN”) guidance, local regulations, state laws, the 2013 Cole Memo, and any subsequent federal guidelines, acts, rules, laws, and regulations which govern
cannabis banking. The CRB Risk Specialist will review and analyze CRB specific suspicious activity monitoring (“SAM”) alerts which trigger in the Bank’s transaction monitoring system, will conduct Cannabis Business Due Diligence (“CBDD”) reviews to include in-person client site visits, CRB Customer Risk Assessments (“CRA”), prepare CRB portfolio reports for review by the CRB Committee, and will prepare and file suspicious activity reports (“SAR”) at CRB customer relationship account opening and every 120 days thereafter. The CRB Risk Specialist will work closely with CRB prospects, applicants, and customers to ensure their activities align with expected activity, and that they are in compliance with the Bank’s policy as well as all applicable state laws and regulations. The CRB Risk Specialist will be a point of contact for the Bank’s CRB customer base and will scrutinize closely the complete enterprise wide banking relationship of the CRB customer base.
This will be Hybrid at our Troy, MI Headquarters with ability to work from home 50% of the time.
Job Responsibilities:
- Review and analyze CRB specific SAM alerts, conduct initial and ongoing CBDD reviews including in-person client site visits, assist in the preparation of CRB Committee presentations, prepare and file SARs, work closely with CRB customer(s) to ensure appropriate account activity and compliance with Bank policy as well as state laws and regulations, and scrutinize the CRB customer’s banking relationship.
- Assist with the revision and maintenance of CRB procedures including working with business lines to provide a comprehensive and controlled customer experience for select CRB customers.
- Train departmental staff in processes, procedures and systems. Acquire knowledge and maintain currency of all compliance, regulatory, and business unit policy, standard and procedure requirements associated with the job. Ensure compliance with applicable federal, state and local laws and regulations. Complete all required compliance training. Maintain knowledge of and adhere to Flagstar's internal compliance policies and procedures. Take responsibility to keep up to date with changing regulations and policies.
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Ensures compliance with applicable federal, state and local laws and regulations. Completes all required compliance training. Maintains knowledge of and adhere to Flagstar’s internal compliance policies and procedures. Takes responsibility to keep up to date with changing regulations and policies.
Job Requirements:
- Bachelor’s Degree Required (Business Administration, Criminal Justice, or related field)
- Seven or more years of BSA/AML or financial industry, investigative, or direct cannabis compliance experience.
- Thorough knowledge of and experience with federal and state AML regulations and requirements, including the Bank Secrecy Act, The USA PATRIOT Act, FFIEC BSA/AML Exam Manual guidelines, OFAC/Economic Sanctions, Suspicious Activity Reporting, and local, state and federal cannabis rules, laws, and regulations.
- Competency in Microsoft Office products
- Knowledge of BSA/AML laws and regulations
- Ability to multi-task and set priorities
- Ability to work independently with minimal supervision
- Ability to display a high level of confidentiality
- Ability to manage alert and case volumes
- Ability to act as liaison between the Bank and CRB customer base with a high level of professionalism, efficiency, and organization
- Excellent analytical, judgement, and research skills
- Positive attitude, enthusiasm, professionalism, and strong work ethic with high level of integrity and ethics.
- Outstanding written and verbal communication skills with demonstrated ability consulting with all levels of an organization
- Team-oriented, great at problem solving, able to juggle multiple priorities and excel in a dynamic and fast moving environment
- Required: Certified Anti-Money Laundering Specialist (CAMS), or Certified Financial Crime Specialist (CFCS), Certified Fraud Examiner (CFE), or Certified Regulatory Compliance Manager (CRCM)
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The job requires a moderate degree of physical exertion and stamina such as standing, sitting, walking, driving or infrequent lifting.
Internal Use Only: Band F
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