BSA / AML Compliance Consultant

The opportunity

We're preparing to launch our first checking account through a sponsor-bank partnership this year. Two adjacent functions 1. BSA / AML compliance and 2. third-party risk management. Both need a senior named owner before the sponsor bank will approve launch. We're combining them into one Consultant role because both are judgment-heavy, sign-off-driven roles whose weekly volume is workable as a single senior practitioner at pilot scale.

We're hiring one experienced operator to wear both hats, build the financial-crimes and vendor-risk programs to bank-grade, and stay on as the senior named owner through the first twelve months of operation.

This is a real seat with real decision authority. The volume of routine work has been deliberately scoped out of the role; what's left is the work that requires senior judgment, risk-rating customers, disposing sanctions matches, signing critical-vendor approvals, leading the SAR escalation framework.

Key responsibilities

BSA / AML compliance

• Author and own the customer risk-rating methodology — business type, geography, ownership patterns, expected activity, adverse media — that scores every customer through onboarding.
• Sign every customer onboarding disposition: approve, decline, hold, or escalate to enhanced due diligence, each with written reasoning recorded.
• Dispose every sanctions partial match against OFAC SDN, EU Consolidated, UK HMT, and UN lists — false positive vs. true hit, with reasoning.
• Lead enhanced due diligence for higher-risk customers and on-board with EDD-tier monitoring where applicable.
• Own the SAR escalation framework. Joint sign-off with the CCO on SAR-candidate cases and FinCEN Form 111 filings.
• Author and own the ongoing customer monitoring program — re-screening cadence, periodic review cycles, escalation triggers.

Third-party risk management

• Own the vendor tiering methodology — critical / material / low, with explicit reasoning per vendor.
• Sign every critical-vendor approval before a contract is executed. Pre-contract gate ownership.
• Lead the annual vendor review cycle for critical and material vendors against the documented inventory.
• Operate the AI / ML vendor model-risk screen with heightened scrutiny — model inventory, validation evidence, human-review configuration, bias controls, data handling.
• Maintain the fourth-party (sub-processor) map for critical vendors and surface concentration risk.
• What you'll deliver in the first ninety days
• By week 4 — Customer risk-rating methodology authored, signed, and live. Vendor tiering framework documented. First synthetic customer dispositions and first critical-vendor approvals recorded against the new methodology.
• By week 8 — Sanctions screening and partial-match SOP fully operational. SAR escalation workflow tested with synthetic cases. Critical-vendor inventory complete with all evidence-currency tracking. AI / ML vendor model-risk screen operational.
• By week 12 — Sponsor-bank diligence at go-live readiness. First controlled customer accounts open under your signed-off risk-rating methodology. Vendor due diligence current across the critical-tier inventory. Operational cadences (weekly customer-onboarding review, monthly leadership reporting, quarterly vendor attestations) running.

What we're looking for

Required

• 6+ years in BSA / AML compliance at a bank, sponsor bank, or fintech program. CAMS certification or equivalent.
• Direct experience authoring or owning a customer risk-rating methodology that survived regulatory or sponsor-bank diligence.
• Operational experience with sanctions screening across OFAC SDN, EU, UK, and UN lists — including partial-match disposition.