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AML Talent, the recruitment arm of Sentinence, is seeking a U.S.-based BSA/AML Officer to lead the company’s AML/CTF and sanctions program. The role combines regulatory strategy with hands-on oversight of transactions, examinations, and program remediation.
You will serve as the designated BSA Officer and primary liaison for FinCEN, regulators, and auditors, reporting to the Global Head of Compliance and the Board.
AML Talent, the recruitment arm of Sentinence.
Our Company is making it easier to buy, sell, and move crypto across Web3, supporting non-custodial on and off-ramp transaction flows. We are building a best-in-class financial screening program to support long-term U.S. scale of operations.
The US Bank Secrecy Act “BSA” Officer carries formal administration for the company’s U.S. Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Sanctions compliance framework.
This role combines high-level regulatory strategy, policy construction, and Board-level reporting with hands‑on oversight of transaction workflows, regulatory examinations, proactive compliance monitoring, and program remediation.
You will serve as the designated BSA Officer and primary point of contact for FinCEN, state financial regulators, and third‑party auditors.
Primary Reporting Lines: Global Head of Compliance (Administrative) and the Board of Directors
1. Proactive Compliance Monitoring & Gap Analysis
Design, execute, and manage an ongoing BSA/AML/Sanctions compliance program
Proactively evaluate control effectiveness across business lines, identifying operational gaps, edge‑case risk vulnerabilities, and any emerging risks before they escalation.
Formulate and drive preventative control enhancements and workflow optimizations to continuously mature the compliance framework.
Track and measure control remediation effectiveness through routine testing cycles of the overall compliance program.
2. Remediation, Audits & Regulatory Examinations
Serve as the primary lead for all U.S. federal (FinCEN, IRS) and state regulatory examinations, as well as independent third‑party BSA/AML effectiveness audits.
Design, advise on, and execute comprehensive remediation programs, historical lookback reviews, and control enhancements to resolve identified deficiencies.
Draft, track, and implement Management Action Plans (MAPs) resulting from internal audits, independent reviews, testing of the compliance program or regulatory findings.
Manage ongoing regulatory engagements, information requests, and supervisory inquiries.
3. Policy, Governance & Board Reporting
Build, maintain, and continuously update U.S. BSA/AML, OFAC Sanctionspolicies, procedures, and internal controls tailored to a non‑custodial crypto model.
Establish U.S.-specific Compliance Key Performance Indicators (KPIs), key risk indicators (KRIs), and operational metrics.
Prepare and deliver quarterly compliance reports directly to the U.S. Board of Directors and Global Head of Compliance.
Conduct annual Enterprise BSA/AML and OFAC Risk Assessments evaluating product, delivery channels, customers, payment methods, geography, and blockchain‑specific risks.
Develop and administer risk‑based BSA/AML and sanctions training for employees, analysts, management, and the Board, and maintain appropriate training records.
Ensure timely completion of applicable BSA reporting, recordkeeping, information‑request, and MSB‑registration obligations.
4. Workflow Management & Analyst Group Oversight
Officer has sufficient authority, budget, staffing, system access, and independence, including authority to elevate matters without management approval.
Provide functional oversight, quality assurance, and technical direction to group AML analysts handling U.S. alert backlogs, investigations, and customer due diligence (CDD/EDD).
Establish standardized investigation guidelines, decisioning trees, and escalation pathways for the analyst group.
Maintain final decision authority on high‑risk customer escalations, blocked transactions, and mandatory SAR filings.
Manage end‑to‑end Suspicious Activity Report (SAR) workflows, including quality reviews, narrative drafting, FinCEN filings, and recordkeeping compliance.
5. Licensing & Regulatory Advisory
Provide ongoing advisory to Executive Leadership, Product, and Engineering on evolving U.S. federal and state regulatory requirements.
Assess compliance readiness and support Legal and Licensing personnel supporting StateMoney Transmitter License (MTL) applications and maintenance, ensuring compliance controls align with state‑specific statutes.
Oversee FinCEN 314(a) mandatory searches and participate in 314(b) voluntary information‑sharing protocols.
6. Systems, Models & Third‑Party Oversight
Oversee the calibration, rule tuning, and threshold testing of transaction monitoring, identity verification (KYC), and blockchain analytics tools.
Validate and challenge third‑party compliance technology vendors, methodologies, and service level agreements (SLAs).
Maintain procedures for sanctions alert escalation, blocking or rejecting transactions when legally required, filing initial blocked‑property and rejected‑transaction reports within 10 business days, and completing annual blocked‑property reporting whenapplicable.
***The candidate must reside in the United States***