We are seeking an experienced Monitoring & Testing Lead to establish and oversee an independent assurance program for fintech and third-party banking relationships. This individual will develop the testing framework, execute risk-based reviews, evaluate control effectiveness, manage findings and remediation, and provide reporting to senior management and governance committees.
The role covers a broad range of partner banking structures and products, including traditional payment activity, digital assets, and stablecoin-related services. This is a hands‑on leadership opportunity for someone who has built or led testing programs and understands the regulatory and operational risks associated with sponsor banking and fintech partnerships.
KEY RESPONSIBILITIES
Monitoring & Testing Program
- Build and maintain a comprehensive monitoring and testing framework for partner banking activities, including methodology, testing procedures, workpaper requirements, evidence standards, quality assurance, and reporting.
- Establish and maintain the testing universe, control inventory, and annual risk‑based testing plan.
- Determine testing frequency and scope based on partner risk, product exposure, regulatory requirements, and broader enterprise and financial crime risk assessments.
- Perform testing directly while developing the function and expand the team as coverage requirements grow.
Partner & Third-Party Control Testing
- Evaluate controls across different partner banking and account structures, including managed accounts, FBO accounts, omnibus arrangements, and similar models.
- Test the effectiveness of controls performed by third parties where the institution relies on fintech partners for KYC/KYB, transaction monitoring, escalation, or other compliance activities.
- Conduct partner oversight reviews and assessments covering BSA/AML, sanctions, fraud, consumer compliance, and operational controls.
- Evaluate whether partner activities remain consistent with approved structures, risk parameters, licensing requirements, and compliance obligations.
BSA/AML & Sanctions Testing
- Test CIP/KYC/KYB, beneficial ownership, customer risk rating, transaction monitoring, alert and case management, SAR processes, and sanctions screening controls.
- Assess transaction monitoring coverage, scenario effectiveness, tuning practices, investigation quality, and escalation processes.
- Evaluate screening and controls involving higher‑risk customers, industries, jurisdictions, counterparties, and transactions.
- Partner with financial crimes and compliance leadership to identify control weaknesses and validate remediation.
- Test reconciliation and recordkeeping controls associated with partner banking and sub‑account structures.
- Assess whether account records and supporting processes meet applicable requirements for deposit account structures and pass‑through deposit insurance treatment.
- Review partner licensing and registration requirements relevant to payment and money transmission activities.
- Trace data and transaction flows across partner integrations to identify gaps between documented processes and actual control execution.
Digital Asset & Stablecoin Testing
- Evaluate controls associated with stablecoin and blockchain‑based payment activity, including conversion activity, issuance and redemption processes, wallet and counterparty screening, and blockchain analytics.
- Assess controls related to Travel Rule requirements, unidentified or unattributed transactions, and digital asset activity occurring outside traditional banking hours.
- Evaluate whether transaction monitoring and sanctions controls appropriately address digital asset and blockchain‑related risks.
Consumer Compliance Testing
- Test partner compliance with applicable consumer protection requirements, including UDAAP/UDAP, Regulation E, Regulation P, and deposit insurance advertising and disclosure requirements.
- Evaluate partner marketing materials, disclosures, complaints, disputes, and other customer‑facing processes.
- Expand testing coverage to applicable lending and credit requirements, including TILA, ECOA, and FCRA, as relevant products are introduced.
Issues, Remediation & Validation
- Document testing findings with clear supporting evidence, risk severity, ownership, and root‑cause analysis.
- Track corrective actions and remediation commitments through completion.
- Independently validate that remediation is effective and supported by sufficient evidence before issues are closed.
- Monitor completion of required partner reviews, conditional approvals, and other risk or compliance commitments.
- Use data analytics, automation, and AI‑enabled tools to improve testing efficiency and expand coverage beyond traditional sampling where appropriate.
- Apply data mapping and full‑population analysis to identify control weaknesses, anomalies, and potential compliance issues.
- Evaluate technology‑supported compliance and due diligence processes to determine whether outputs are accurate, complete, and appropriately controlled.
Leadership & Regulatory Support
- Recruit, develop, and manage monitoring and testing professionals as the function grows.
- Establish consistent testing and documentation standards and provide quality oversight across the team.
- Present testing results, significant control deficiencies, trends, and remediation status to senior management and governance committees.
- Support regulatory examinations and internal audits by preparing testing documentation, evidence, responses, and remediation updates.
- Monitor supervisory guidance and enforcement developments affecting fintech partnerships, third‑party banking, and digital assets and incorporate relevant changes into testing coverage.
QUALIFICATIONS
- 8+ years of experience in compliance monitoring and testing, internal audit, risk management, or compliance within banking or financial services.
- Direct experience testing fintech partner, sponsor bank, BaaS, or comparable third‑party banking programs.
- Demonstrated experience building or leading a risk‑based monitoring and testing program, including ownership of the testing universe, annual plan, methodology, issue management, and senior‑level reporting.
- Experience testing or auditing partner banking structures such as managed accounts, FBO accounts, omnibus arrangements, or similar models.
- Experience evaluating reliance on third‑party KYC/AML controls as well as related recordkeeping and reconciliation processes.
- Experience conducting fintech partner oversight reviews covering BSA/AML, sanctions, fraud, consumer compliance, and related controls.
- People management experience, including developing and overseeing testing, audit, compliance, or risk professionals.
- Working knowledge of consumer protection requirements applicable to fintech partnerships, including UDAAP/UDAP, Regulation E, Regulation P, and applicable deposit insurance advertising and disclosure requirements.
- Familiarity with regulatory expectations governing third‑party relationships, sponsor banking, and fintech partnerships.
- Experience presenting significant findings to senior management or governance committees and supporting federal banking examinations.
- Experience managing findings, overseeing remediation, and independently validating corrective actions through closure.
PREFERRED QUALIFICATIONS
- Experience testing digital asset or stablecoin controls, including blockchain analytics, wallet screening, counterparty screening, or Travel Rule requirements.
- Familiarity with money transmission, MSB, digital asset, or similar licensing and registration requirements.
- Experience addressing significant regulatory findings, supervisory matters, or formal remediation programs through closure.
- Experience within a federally regulated bank or active sponsor banking environment.
- Familiarity with GRC, audit management, data analytics, AI‑enabled compliance, or similar technology platforms.
- CAMS, CRCM, CIA, CPA, or another relevant professional certification.