Analyst I, II BSA Bank Secrecy Act

Position Function:

Responsible for implementing various aspects of the Bank's Bank Secrecy Act (BSA)/ Anti-Money Laundering (AML)/ Office of Foreign Assets Control (OFAC) Program.

Performs all duties and interacts with internal and external customers in a manner that is expressly aligned with the Company's Core Values of approaching all actions with a “Voyaging Spirit” and being “Positively Ohana”. Exhibits core competencies that result in consistent delivery of positive Customer Interactions, Empowerment and Ownership and demonstrates key professional and performance skills such as Active Listening, effective Oral and Written Communication, Action and Solution Oriented and Thoroughness.

Primary Accountabilities:

BSA Compliance Program

• BSA Policies and Procedures: Maintain department-level and bank-level policies and procedures, recommend changes to procedures or processes to improve program effectiveness, and assist the business units in developing and maintaining their BSA-related processes and procedures.
• BSA Training: Conduct or facilitate BSA training for employees.  Develop and maintain the BSA content on the Compliance Connect page on the intranet.  
• Record Retention: Maintain records and documentation of the Bank’s BSA compliance program and its elements, in the form and substance necessary to demonstrate the Bank’s fulfilment of BSA requirements.     

Customer Identification Program, Customer and Enhanced Due Diligence, and Customer Risk Ratings Customer Identification Program (CIP):   

• Facilitate the Bank’s CIP, including monitoring and testing of the CIP, as necessary and appropriate.
• Customer and Enhanced Due Diligence (CDD and EDD): Facilitate the identification of potential high-risk customers at account opening, through account monitoring, and through the BSA software.  Conduct and document EDD reviews.
• Customer Risk Ratings: Make recommendations on the final risk ratings through the CDD and EDD processes, including recommendations for additional monitoring, the filing of a Suspicious Activity Report (SAR), and/or account closure.
• Suspicious Activity Reporting, Currency Transaction Reporting, and Other Regulatory Filings
• Suspicious Activity Reporting: Review and analyze potential SAR activity; determine whether to file the SAR and document the SAR decision by completing the SAR or documenting the non-SAR; and recommend any other actions, including account closure.

Currency Transaction Reporting:  

• Review and file CTRs in accordance with the regulatory requirements.  Recommend customers for CTR exemptions, as appropriate, and monitor, file and periodically review all CTR exempt customers within the required timeframes.
• Other Regulatory Filings: Facilitate all other regulatory filings, including but not limited to foreign bank and financial accounts reporting and the international transportation of currency or monetary instruments.
• Information Sharing
• Facilitate proper compliance with 314(a) requests, special measures, and other governmental inquiries and requests, as well as compliance with any 314(b) information sharing.
• Office of Foreign Assets Control
• Facilitate the administration of the Bank’s Office of Foreign Assets Control (OFAC) Program.

BSA Knowledge & Support 

• BSA Knowledge: Keep abreast of the BSA and all related regulations.  Understand the Bank’s products, services, customers, entities, and geographic locations, and the potential money laundering and terrorist financing risks associated with the Bank’s activities.
• BSA Support: Provide BSA support and guidance to the Bank and respond to branch and department inquiries into BSA matters.   

BSA Reporting, Audits, and Examinations

• Audits and Examinations: Assist the BSA audits and examinations, and any corrective action that is taken for any actual or potential BSA compliance issues or violations.

Minimum Qualifications:

Education:

• BSA Analyst I - Associate’s Degree from an accredited higher-level learning institution preferred.
• BSA Analyst II - Associate’s Degree from an accredited higher-level learning institution required.

Experience:

• BSA Analyst I 
  • 2 years of experience in bank compliance, audit, examination, and/or legal experience (A bachelor’s degree can substitute for 2 years of work experience.)
  • BSA experience preferred.
  • Knowledge of banking laws, rules and regulations is highly desirable.
• BSA Analyst II
  • 3 years of experience in bank compliance, audit, examination, and/or legal experience (A bachelor’s degree can substitute for 2 years of work experience.)
  • BSA experience preferred.
  • Knowledge of banking laws, rules and regulations is highly desirable.

Physical Requirements & Working Conditions:

• Must be able to perform light physical work and to move or lift items including but not limited to boxes, files and papers up to 20 pounds unless otherwise as indicated.
• Must be able to operate and proficiently use standard office equipment, including phone, copier, personal computer and/or other work related mechanical or electronic devices and applications.
• Must be able to clearly communicate verbally and in writing with all internal and external customers. Must also be able to hear sufficiently to engage in daily discussions and interactions.
• Must be able to read and understand bank-related documents. 
• Must be able to work in a conventional office setting, involving sitting at a desk or workstation for long periods of time.  Must also be able to adapt to different work environments as needed to perform the job.

We are proud to be an EEO/AA employer M/F/D/V. We maintain a drug-free workplace and perform pre-employment substance abuse testing.