Sr. Analyst Cannabis AML Compliance

Responsibilities Include:

Perform and document high-risk cannabis account investigations and research to address any account irregularities and determine whether Suspicious Activity Report (“SAR”) reporting is warranted, adhering to Cannabis Related Business (“CRB”) SAR filing rules and relevant red flags. Prepare any other required SARs and Currency Transaction Reports (“CTR”), as warranted, ensuring accuracy and adherence to filing requirements and filing timeframes.

Conduct initial and regular due diligence and recommend appropriate risk-based business actions to be taken concerning member relationship, profile, and accounts during onboarding or ongoing monitoring and escalate as necessary. Recommend a course of action, along with supporting documentation, to management for approving or declining new applicants, restricting accounts and services, or terminating an existing relationship, based on an analysis of findings.

Review all new and existing customer portfolios/accounts to ensure all Customer Identification Program (“CIP”), customer due diligence, and Beneficial Ownership information and documentation have been obtained, are valid, and meet our Program requirements; assist in communicating with CRB Relationship Manager to ensure that missing, incomplete, or incorrect items are obtained or rectified.

Verify with the appropriate state authorities whether the business is duly licensed and registered; review the license application, and related documentation, submitted by the business for obtaining a state license to operate its Cannabis Related Business. Conduct criminal background checks on principal owners (5% or more) and/or angel investors of the business prior to account opening, perform negative news media searches, and conduct checks new owners of the business as they are added.

Assist management in maintaining an effective Customer Due Diligence ("CDD") and Enhanced Due Diligence ("EDD") risk rating and monitoring program for all CRB accounts to include initial and ongoing risk assessments, and review and analysis of unusual/suspicious account activity

Keep abreast of and analyze developing industry and compliance trends and changes to laws and regulations applicable to BSA/AML, OFAC, the USA PARTIOT Act, and CRB BSA/AML banking and compliance guidelines. Ensure credit union operations, internal policies, procedures, and controls are compliant.

Assist management with BSA, AML, OFAC, and CRB risk assessments as needed with consideration to products, services, members, and geographies that may present BSA, AML, OFAC, and CRB BSA/AML risks.

Serve as a subject matter expert (SME) on escalated AML detection and investigative issues, and research and respond to BSA/AML and OFAC and CRB BSA/AML compliance questions posed by Credit Union leaders and staff.

Assist in the enhancement, development, implementation, and administration of the BSA, AML, OFAC monitoring systems to ensure that appropriate parameters are in place to identify suspicious and/or fraudulent activity.

Perform other CRB Program or ad hoc BSA, AML, OFAC tasks as assigned.