Description:
The primary responsibility of the KYC High Risk Reviews team is to execute enhanced due diligence (EDD) reviews for high-risk customers at the bank. The team is responsible for managing procedures and escalations related to high-risk customers, including analysis of customer behavior and activity of concern, in compliance with KYC policy and regulatory requirements. The team engages with the 1st line of defense on the outcomes of EDD reviews, management of issues, and guidance related to high-risk customer types and associated activity.
Depth & Scope
- Performs holistic Enhanced Due Diligence (EDD) reviews on high-risk customers at onboarding, periodic review, and event driven reviews, ensuring compliance with internal policies and external regulations
- Reviews customer risk factors/indicators, and acts as a subject matter expert to understand and assess the identified customer risk and how it relates to the Bank products/services to further determine if those risks can be mitigated
- Responsible for documenting the assessment and providing a recommendation based on the independent analysis to maintain and/or onboard the customer
- Evaluates and assesses customers' source of funds, business activities, ownership structures, and other risk factors
- Reviews, assesses, and analyzes customer transactional activity to determine if customer's activity is aligned to the customer KYC profile and expected use of customer's accounts
- Engages with the 1st line of defense on the outcomes of EDD reviews and guidance related to high-risk customer types and associated activity
- Ensures adherence to AML regulations, the Bank Secrecy Act (BSA), Office of Foreign Assets Control (OFAC) requirements, and other applicable laws
- Proactively identifies trends and emerging risks in high-risk customer profiles, escalates issues and recommends controls or mitigation measures
- Maintains up-to-date knowledge of regulatory changes and industry best practices, applying this expertise to enhance the KYC program
- Prepares detailed, well-documented EDD risk assessment narratives and provide risk recommendations to support decision-making for senior management and regulators
- Provides data-driven insights and recommendations for process improvements, ensuring the effectiveness of the high-risk customer review process
- Collaborates with internal stakeholders to address gaps or deficiencies in KYC or financial crime risk management frameworks
- Serves as a subject matter expert (SME) on KYC and EDD processes for high-risk customer reviews, providing training and guidance to junior analysts or team members
- Represents the Financial Crime Risk Management team during internal and external audits or regulatory examinations
- Leads projects or initiatives focused on enhancing the bank's high-risk customer review processes and risk mitigation strategies
- Utilizes independent judgment to develop and implement policies, procedures, and best practices for high-risk customer management
- Supports the Group Manager by assisting with day to day tasks and acting as a delegate as needed
Education & Experience
- Bachelor’s degree in Business, Finance, Law, Criminal Justice, or related field
- Advanced certifications such as CAMS, or equivalent are strongly preferred
- 5+ years of experience in KYC, EDD, or AML within a financial institution
- Demonstrated expertise in high-risk customer reviews and regulatory compliance
- Strong analytical, problem-solving, and decision-making skills
- Excellent written and verbal communication skills, with the ability to present complex findings to stakeholders
- Proficiency in AML software and tools, as well as Microsoft Office Suite
- Ability to exercise significant discretion and independent judgment in assessing and managing risks
- Ability to manage multiple high-priority tasks and deliver results under tight deadlines
- Demonstrated leadership or project management experience preferred