BSA/AML Compliance Officer

Distro; San Juan (PR); On-site; USD 120,000 - 150,000; Full time

Job summary

OliBank in Puerto Rico is seeking a designated BSA/AML Officer to own and drive a risk-based compliance program across MSB and banking activities. You will manage SAR determinations, reporting, and OFAC screening governance.

You will work closely with the Board and cross-functional teams to ensure compliance with FinCEN and OCIF expectations, including vendor reviews and risk assessment activities. Fluency in English is required with Spanish a plus.

Qualifications

• 3+ years BSA/AML compliance experience in a regulated financial institution.
• Hands-on SAR lifecycle experience: investigation, memos, filing clocks, continuing activity.
• Knowledge of FinCEN/OFAC/MSB obligations and related regulations.
• Strong research, writing, and Board-level communication skills.

Responsibilities

• Own and maintain the risk-based BSA/AML compliance program across MSB and bank programs.
• Serve as designated BSA Officer with SAR determinations and 14- day review windows.
• Report to the Board on program health, trends and deficiencies; provide metrics.
• Govern sanctions screening governance: OFAC, screening outages, and ownership handling.
• Audit and improve KYB artifacts, monitoring alerts, and residual risk.
• Manage vendor and counterparty compliance touchpoints and sign-offs.

Skills

BSA/AML compliance

SAR lifecycle

OFAC compliance

Regulatory exams

Education

University degree in law/finance/business

Job description

About OliBank

OliBank's mission is to make managing finances as easy as possible. Our vision is an evenly distributed, global, digital-first financial system that levels the playing field.

Our values~ Sense of Urgency, Customer Obsession, Pride in Craftsmanship.

How we work~

• Culture eats strategy — everyone owns it, everyone can be held accountable to it.
• Culture of ownership — keep the bar high, own decisions, correct and learn.
• Long-term results over short-term wins — with urgency.
• Build great systems, make the complex simple, use forcing functions.
• Obsess over the details (culture, customers, product, process, data).
• Bias for action, be bold, disagree-and-commit, end with the positive — and mistakes have consequences. There is always room for improvement.

Compliance at OliBank is not a back office. It is how we earn the right to move money globally. This role owns that.

The role Designated BSA/AML Officer. You own a risk-based BSA/AML/OFAC compliance program that satisfies FinCEN, OFAC, and OCIF expectations for a FinCEN-registered MSB operating with a Puerto Rico IFE — including SAR decisioning authority, FinCEN 314(a) handling, sanctions screening governance, and Board reporting.

Main responsibilities

BSA/AML program ownership

• Own and maintain the risk-based BSA/AML compliance program (CIP/KYB/KYC, beneficial ownership, EDD, ongoing monitoring, recordkeeping) across the MSB and bank programs, with clear capacity-split documentation for each decision.
• Serve as designated BSA Officer with authority for SAR determinations, SAR filing clocks (31 CFR 1020.320), continuing-activity reviews, confidentiality/no-tipping, and 314(a) searches (14-day window, no-hit logs, no disclosure to subjects).
• Report directly to the Board on program health, trends, and deficiencies — trends and metrics, never case-file detail in minutes. Sanctions & screening
• Govern sanctions screening~ direct OFAC SLS ingestion/reconciliation, ITA CSL / EU / UK sources, OFAC 50 Percent Rule ownership handling, pre-submission beneficiary screening, fuzzy-match disposition, and fail-closed behavior on screening outages.
• Own OFAC block/reject handling (31 CFR 501.603/601.604, 10-business-day reporting) — confirmed matches block; auto-return/retry only after false-positive disposition. Client lifecycle & transactions
• Evaluate onboarding, EDD triggers (high-risk jurisdiction, complex ownership, volume, PEP/sanctions), and transaction activity for compliance risk.
• Proactively audit processes, KYB artifacts, monitoring alerts, and CIS risk-scoring dispositions; document findings, remediations, and residual risk.
• Own vendor and counterparty compliance touchpoints~ compliance sign-off on vendor reviews where BSA/AML screening or monitoring is implicated.

Controls, training, culture

• Build simple, systemic internal controls with forcing functions — not one-off customizations. No "100% guarantee" language; design for reasonable, risk-based, auditable compliance.
• Own the training program (staff, engineering/CIS, Board orientation, alternate/interim BSA coverage).
• Manage independent testing / audit remediation, examiner requests (OCIF, IRS BSA exam for MSB), and the residual-risk register.

Experience required

• 3+ years BSA/AML compliance experience in a regulated financial institution; direct experience with a Puerto Rico IFE / OCIF examination cycle required.
• Hands-on SAR lifecycle~ investigation, determination memos, filing clocks, continuing activity, confidentiality. Must be able to evidence SAR decisioning authority.
• Working knowledge of BSA recordkeeping, funds-transfer recordkeeping (
• 1010.410), FinCEN 314(a), OFAC administration, and MSB obligations (31 CFR Part 1022 vs. bank Part 1020/CIP differences).
• Experience with transaction monitoring / risk-scoring systems, KYB/KYC vendors, and audit of alert dispositions (false-positive rationale discipline).
• Risk management and/or financial-crimes audit experience (2+ years).
• Strong research, writing, and Board-level communication skills. Fluent English required; Spanish a strong plus (OCIF/market reality).
• Integrity, independence of judgment, and willingness to veto — disagree-and-commit cuts both ways; the BSA decision is yours. Strongly preferred
• Professional certification~ CAMS, CGSS, CRCM, or equivalent.
• Stablecoin / cross-border payments experience.
• Data-protection literacy (GDPR concepts); privacy-framework experience is a plus, not core.

Education

• University degree in law, finance, business administration, or related field. JD or advanced degree a plus, not required.

Location~

Must be located in or self-relocating to Puerto Rico

#OliBank

We may use artificial intelligence (AI) tools to support parts of the hiring process, such as reviewing applications, analyzing resumes, or assessing responses and identifying potential inconsistencies or verification signals in application materials based on available information. These tools assist our recruitment team but do not replace human judgment. Final hiring decisions are ultimately made by humans. If you would like more information about how your data is processed, please contact us.