We are seeking an experienced compliance assurance leader to establish and oversee an independent monitoring and testing program supporting a growing bank-fintech partnership business.
This is a build-and-lead role for someone who can create a testing framework from the ground up while remaining hands-on with execution. The position will evaluate controls across multiple partner operating models, including programs where the bank performs customer due diligence and transaction monitoring directly and arrangements where certain compliance activities are performed by a fintech or other regulated partner.
The environment includes traditional banking and payment products as well as digital-asset and blockchain-enabled activity. The successful candidate will combine strong banking compliance testing experience with an understanding of sponsor banking, third-party oversight, BSA/AML, consumer protection, and emerging financial technologies.
What You’ll Own
- Build the monitoring and testing program. Design the methodology, testing procedures, documentation requirements, workpaper standards, quality review process, evidence expectations, and management reporting framework.
- Develop risk‑based coverage. Create and maintain the control inventory and testing universe, establish the annual testing schedule, and determine testing frequency and depth based on partner risk, enterprise risk assessments, and financial crime exposure.
- Evaluate partner compliance programs. Independently assess controls performed by fintech and other third‑party partners, including KYC/KYB, beneficial ownership, customer risk classification, transaction monitoring, escalation practices, and other activities on which the bank relies.
- Test financial crime controls. Review BSA/AML and sanctions processes, including onboarding, screening, monitoring scenarios and tuning, alert investigations, case management, SAR processes, OFAC controls, high‑risk geographies, and restricted customer or business categories.
- Assess sponsor banking structures. Test controls associated with managed account, FBO, omnibus, and similar program structures, including the effectiveness of bank and partner responsibilities under each model.
- Review account records and reconciliation. Evaluate reconciliation between partner‑level or virtual account records and bank systems, including recordkeeping necessary to support applicable deposit insurance treatment.
- Test digital‑asset activities. Assess controls involving stablecoins, blockchain‑based payments, wallet and counterparty screening, blockchain analytics, conversion activity, token issuance/redemption processes, Travel Rule information, unidentified incoming transfers, and continuous transaction processing.
- Evaluate consumer compliance. Test partner‑facing and end‑customer requirements involving UDAAP/UDAP, Regulation E, Regulation P, deposit insurance advertising and disclosure requirements, and bank approval of partner marketing. Coverage may expand to TILA, ECOA, FCRA, and related requirements as lending and card products develop.
- Review licensing and registration. Confirm that partner activities and operating structures are consistent with applicable state money transmission licenses, federal MSB registrations, virtual‑currency licensing, and similar regulatory requirements.
- Manage findings and remediation. Establish clear issue‑rating and documentation practices, identify root causes, assign accountability, monitor remediation, and independently validate corrective actions before closure.
- Use technology to broaden assurance coverage. Incorporate data analytics, data lineage/mapping, AI‑assisted tools, and full‑population testing where appropriate. Evaluate the reliability of automated or AI‑supported compliance processes used by partners or the bank.
- Lead partner reviews. Conduct or oversee compliance assessments and onsite reviews of fintech partners, evaluating financial crime, sanctions, fraud, consumer compliance, governance, and control effectiveness.
- Support regulatory and audit activity. Provide documentation and subject‑matter support for federal banking examinations and internal audit reviews and incorporate new supervisory expectations and enforcement themes into the testing program.
- Build and lead the team. Hire and develop testing professionals as the program expands while personally executing higher‑risk or specialized reviews during the buildout phase.
- Report to senior governance. Communicate testing results, significant control weaknesses, emerging risks, and remediation status to senior executives, governance committees, and Board‑level audiences.
What We’re Looking For
Candidates should bring:
- 8+ years of experience in banking compliance testing, monitoring, internal audit, compliance assurance, or closely related risk functions.
- Direct experience with sponsor banking, Banking‑as‑a‑Service, embedded finance, or fintech partnership oversight, including hands‑on testing of partner compliance processes.
- Demonstrated ownership of a monitoring or testing program, including creation of the testing universe, risk‑based annual plan, methodology, issue‑management process, and executive reporting.
- Experience reviewing FBO, omnibus, managed account, or comparable sponsor‑bank structures, including situations where the bank relies on a partner's KYC/KYB or AML controls.
- Knowledge of sub‑account recordkeeping, ledger reconciliation, and controls supporting pass‑through deposit insurance requirements.
- Hands‑on experience assessing fintech partners through compliance reviews, control testing, or onsite examinations, with exposure to BSA/AML, sanctions, fraud, and consumer compliance.
- Strong knowledge of KYC/KYB, beneficial ownership, customer risk rating, transaction monitoring, SAR processes, sanctions screening, and related financial crime controls.
- Experience recruiting, coaching, or managing compliance testing, audit, or assurance professionals.
- Ability to operate as both a program leader and an individual contributor in an evolving environment.
- Working knowledge of consumer banking requirements relevant to fintech programs, including UDAAP/UDAP, Regulation E, Regulation P, and FDIC deposit insurance advertising rules, with familiarity with TILA, ECOA, and FCRA.
- Experience supporting federal banking regulators and presenting testing or assurance results to senior management or Board‑level committees.
- Experience validating remediation and closing regulatory, audit, or compliance findings based on documented evidence.
Particularly Valuable Experience
Experience in one or more of the following areas will be especially relevant:
- Stablecoins, blockchain payments, digital assets, or other crypto‑related banking activity.
- Wallet screening, blockchain analytics, digital‑asset transaction monitoring, Travel Rule compliance, or stablecoin issuance/redemption controls.
- State money transmitter licensing, FinCEN MSB registration, virtual‑currency licensing, or international VASP frameworks.
- Remediation of regulatory matters such as MRAs, enforcement actions, or consent‑order requirements through validated closure.
- Current regulatory expectations governing bank‑fintech partnerships and third‑party risk management, including applicable interagency guidance and OCC supervisory publications.
- Data mapping, automated testing, AI‑enabled compliance technology, or testing of AI‑supported due diligence processes.
- Experience with compliance, audit, or GRC platforms such as Archer, TeamMate, or comparable systems.
- Experience within a national bank, sponsor bank, or financial institution with a significant fintech partnership portfolio.
- Professional certifications such as CAMS, CRCM, CIA, or CPA.