We are seeking an experienced Foreign Correspondent Banking Analyst to support compliance oversight of international correspondent banking relationships. This role will conduct enhanced due diligence on foreign financial institutions, assess country and institution risk, review correspondent account activity, and support ongoing monitoring and regulatory requirements.
The position is ideal for a hands‑on financial crimes professional with strong correspondent banking knowledge who is comfortable evaluating complex foreign financial institutions, international payment activity, and higher‑risk jurisdictions.
KEY RESPONSIBILITIES
- Conduct enhanced due diligence reviews of foreign financial institutions, including analysis of Wolfsberg questionnaires, AML/CFT programs, ownership information, PEP exposure, regulatory history, and other supporting documentation.
- Assess prospective and existing correspondent relationships across factors such as ownership, business activities, regulatory standing, financial condition, AML controls, adverse information, and information security risk.
- Evaluate geographic risk using recognized sources and frameworks, including FATF publications, OFAC sanctions programs, the Basel AML Index, Transparency International data, and other relevant indicators.
- Prepare written due diligence assessments, risk‑rating rationale, and supporting materials for senior compliance and management review.
- Coordinate with relationship management teams to obtain required documentation, resolve information gaps, and track outstanding requests.
Ongoing Monitoring & Reviews
- Manage periodic reviews of assigned correspondent banking relationships, including documentation refreshes, transaction analysis, AML program reassessments, and updates to institution and country risk ratings.
- Conduct event‑driven reviews following material developments such as sanctions changes, FATF updates, enforcement actions, suspicious activity, adverse media, ownership changes, or unusual transaction patterns.
- Review and disposition transaction monitoring alerts involving correspondent accounts, including unusual volumes or values, geographic concerns, layering patterns, and potential nested correspondent activity.
- Identify material changes in relationship activity and elevate higher‑risk findings in accordance with established procedures.
- Support relationship termination and wind‑down activities when correspondent relationships require exit.
AML, SAR & Regulatory Support
- Draft SAR narratives and supporting case documentation involving correspondent banking activity.
- Assist with requirements related to foreign shell banks, ownership updates, and applicable USA PATRIOT Act provisions governing foreign correspondent relationships.
- Support responses to government and regulatory inquiries involving foreign correspondent accounts.
- Maintain complete due diligence, investigation, approval, and monitoring records suitable for regulatory examination.
- Assist with regulatory examinations and information requests by organizing relevant correspondent banking documentation and case materials.
Program Support
- Provide feedback on transaction monitoring scenarios, due diligence processes, risk assessment methodologies, and investigative workflows.
- Identify documentation deficiencies, recurring alert issues, and emerging correspondent banking risks.
- Partner with Compliance, Legal, Operations, Relationship Management, and other internal stakeholders on correspondent banking matters.
- Contribute to training and knowledge‑sharing related to correspondent banking compliance and financial crime risk.
QUALIFICATIONS
- 5–7 years of progressive experience in correspondent banking, BSA/AML compliance, sanctions compliance, foreign financial institution due diligence, or financial crime investigations within a U.S. bank, foreign bank branch, regulatory agency, or similar environment.
- Professional fluency in Spanish, including the ability to read, write, and communicate effectively with Spanish‑speaking clients and stakeholders.
- Working knowledge of the USA PATRIOT Act requirements applicable to foreign correspondent banking, including Sections 312, 313, and 319(b).
- Strong understanding of BSA/AML requirements, OFAC regulations, FinCEN requirements, and regulatory expectations for correspondent banking.
- Hands‑on experience reviewing Wolfsberg CBDDQ responses, AML program materials, and other foreign financial institution due diligence documentation.
- Experience evaluating country and jurisdictional risk using sources such as FATF, OFAC, the Basel AML Index, and Transparency International.
- Familiarity with international and domestic payment systems, including SWIFT, CHIPS, Fedwire, ACH, and real‑time payment networks.
- Experience preparing due diligence assessments, risk analyses, investigation memoranda, SAR narratives, or other compliance documentation for senior‑level review.
- Strong investigative and written communication skills with the ability to manage multiple reviews and alerts within established timelines.
PREFERRED QUALIFICATIONS
- CAMS or another relevant financial crimes compliance certification.
- Experience working within a federally regulated or nationally chartered banking environment.
- Familiarity with regulatory examination expectations applicable to foreign correspondent banking.