Compliance Officer

The Compliance Officer is responsible for developing, implementing and administering all aspects of VeriCheck’s Compliance Management Program. This position should have a strong understanding of the operational compliance risk within the Payments Industry. This position plans, organizes, and controls the day-to-day administrative and operational compliance activities. This position will be responsible for performing various quality controls reviews and monitoring pertaining to the Bank Secrecy Act, USA Patriot Act, Anti-Money Laundering Program, OFAC, Customer Identification Program compliance and Beneficial Ownership requirements, NACHA Rules and other regulatory guidance as applicable. Collaborates with the Board, Chief Operating Officer, Chief Information Officer, Risk Committee and Director of Operations in the overall administration of these directives. Participates in various committees, audits and examinations. Conducts staff training related to new hires, compliance, customer service, marketing initiatives and certain IT-related implementations. Advises Senior Management and all other personnel of emerging compliance issues. Consults and guides VeriCheck in the establishment of controls to mitigate risks. The Compliance Officer reports directly to the CEO.

The Compliance Officer supports the company enterprise-wide, providing compliance risk expertise for projects and initiatives. Manages the remediation efforts resulting from internal and/or external compliance audits or examinations. Works with business units to identify and resolve issues and implements resulting action plans to address deficiencies. Designs and coordinates the preparation and responsible for the review of policies, procedures, training materials and other communications to ensure compliance with applicable state and federal laws and regulations. Develops and implements a compliance testing program including methodologies for remediation. Serves as a subject matter expert regarding compliance risk with new products and processes and provides recommendations to mitigate risk. The position requires intense communication, negotiation and problem solving along with thorough knowledge of Payments processing, ACH, Bankcard, operational risk management, consumer protection compliance and IT regulations.

DUTIES:

• Ensure the development and maintenance of the CMS, BSA/AML (including CIP)OFAC, ACH Compliance, Information Security and Consumer Protection Compliance policies, procedures and controls;
• Facilitate and Maintain the Annual Risk Assessment
• Monitor and test controls
• Coordinate CMS, BSA/AML (including CIP)OFAC, ACH Compliance, Information Security, Consumer Protection Compliance Audit and Examinations
• Identify and implement new rules, laws, regulations and trends related to compliance or that impact VeriCheck’s operations
• Develop/Implement plans for addressing compliance violations, criticisms, findings of auditors and regulators.
• Implement CMS, BSA/AML (including CIP), OFAC, ACH Compliance, Information Security & Data Security Awareness and Consumer Protection Compliance Training Programs.
• Develop and Implement a robust program for documenting merchant training activities and maintain documentation of training and communication provided to merchants.
• Manage the Customer Identification Program (CIP) and maintain the annual BSA/AML risk assessment process.
• Deliver Monthly Reports to the Board of Directors that will:
• Develop and implement a documented Suspicious Activity Monitoring and Reporting Program that is addressed in policies and procedures.
• Develop and implement a documented Consumer Complaint Monitoring and Reporting Program that is addressed in policies and procedures.
• Communicate potential fraud and high-risk account alerts to appropriate areas
• Administer FinCEN 314a CIF database scrubbing
• Administer SIR filings and SIR administration
• Attend conferences, seminars, webinars and other educational forums as appropriate.

• Facilitate the implementation and annual review of all policies and procedures
• Ensure policies remain in alignment with VeriCheck’s business processes and state and federal laws and regulations.
• Ensure any changes to policies and procedures are communicated to staff
• Ensure evidence of the review of all policies and procedures is documented

• Initiate updates to the risk assessment more frequently, if circumstances warrant
• Keep policies and procedures in alignment with risk assessment
• Keep control testing schedule in alignment with risk assessment

• Implement and maintain internal control testing schedule
• Ensure testing schedule is in alignment with the risk assessment
• Facilitate testing of controls and document results
• Facilitate corrective action and report to the Board
• Update policies, procedures, training, agreements, etc., as necessary, based upon any control failures

• Develop and maintain an audit/examination schedule
• Act as the primary point of contact with auditors and examiners
• Coordinate audit/examination preparation and response
• Manage and report any corrective action required
• Maintain documentation of audit/examination

• Develop and Implement a robust documented compliance training program and maintain documentation of employee training

• Identify deficiencies in the overall compliance management system and report on progress of corrective action.
• Identify and report changes in applicable laws, rules or regulations
• Provide a summary of consumer complaints received and their resolution
• Maintain and report Suspicious Activities, and any Suspicious Incident Reports filed with respective ODFIs
• Develop and maintain a Merchant Watch List
• Report on internal and external control testing audit/examination results and resolutions
• Maintain documented evidence of periodic review by the Board

• Act as the subject matter expert relating to suspicious activity
• Determine appropriate action and document actions taken

• Act as the central point of communication for suspicious activity
• Determine appropriate action and document actions taken

QUALIFICATIONS:

• Communicate effectively (written and verbally) with internal and external associates
• Excellent organizational and analytical skills
• Must maintain a high level of accuracy in performance in a high-speed environment
• Proficiency with Microsoft applications
• Strong understanding of the Payments industry, underwriting and operational risk management
• 5-7 years banking and/or payments experience of which 5+ years in Operations or Compliance or Risk
• Working knowledge of BSA/AML Compliance rules and regulations, Consumer Protection, Reg E, UDAAP, NACHA Rules, etc.
• Compliance Certification or AAP strongly encouraged
• Experience with managing compliance related to the Payments industry from both a ODFI perspective as well as a TPPP perspective

EDUCATION AND/OR EXPERIENCE:

• College graduate
• Compliance Certifications (strongly encouraged/preferred)