BSA Analyst

Summary Assists in ensuring the Bank’s compliance with the applicable aspects of the Bank Secrecy Act, USA Patriot Act and OFAC regulations by monitoring activity for potential money laundering, financial crimes and/or terrorist financing and by tracking exceptions and filing required transaction reports by performing the following duties.

Duties and Responsibilities include the following.

• Transaction Monitoring/Alerts
  • Analyzes alerts generated from an automated detection system BAM+, differentiating between suspicious and legitimate transactions conducted by the customer.
  • Identifies and analyzes possible money laundering activity by reviewing customer transactional patterns reported by non-BSA bank employees via QAR+; opening or moving those that are not cleared to Alert for further investigation.
  • Applies logic and AML knowledge to investigations on a case by case basis, recognizing the subjective nature of each individual alert or referral from non-BSA employees.
  • Performs diverse and complex analysis of potentially suspicious customers, accounts and activities.
  • Reviews, researches and makes determination of suspicion on items and transactions identified in reviewing assigned reports in BAM; opening Alerts or Cases for those requiring further review.
  • May utilize information found on subscribed background information system (CLEAR) as well as the public domain to complete activity analysis and make informed conclusions.
  • Ensures accuracy of documenting and tracking of alert disposition, properly indicating decisions to clear or refer for further investigation.
  • Prepares concise, yet thorough, alert investigation summaries outlining relevant details to support a final outcome.
  • Compiles organized, well supported synopses for AML-related referrals to Case from Alerts.
  • Identifies and refers high risk entities and consumers to the CDD/EDD Analyst for further action.
  • Completes all job-related training in a timely manner and attends seminars or continuing education, as directed and monitor required continuing education credits.
  • Develops an understanding of the industry and AML related regulations as well as patterns of behavior that represent suspicious activity and stays up-to-date on changes in the industry.

Duties and Responsibilities include the following.

• CIP/CDD/EDD
  • Monitors all new customers/accounts for the required CIP information/CDD documentation and tracks missing CIP/CDD information for follow-up.
  • Monitors all new customers for completed ID Verification and proper resolution of any failed results utilizing core systems and reports.
  • Reviews identification documents provided by new business customers for appropriateness based on business type and for accuracy in account setup based on document.
  • Reviews every customer (existing and new) for new accounts opened to determine the initial or new risk rating at the account level. Records risk rating in BAM and assigns those that score in the high risk category with the appropriate tag in BAM for further review.
  • Responsible for on-going tracking of exceptions totals for CIP, CDD, Document and OFAC to report to Bank Management monthly.
  • Identifies and refers high risk entities and consumers or identified suspicious activity to the CDD/EDD Analyst for further action if applicable.
  • Reviews other reports as assigned to determine if all CIP and CDD processes are followed.
  • May be assigned alerts in BAM+ for Red Flags or New Account scenarios to review and determine if the alert can be cleared or needs further action.
  • Performs scheduled Enhanced Due Diligence (EDD) reviews of accounts deemed as high risk, including but not limited to MSBs, NBFIs, etc.; documents EDD monitoring and tags accounts appropriately in BAM (online BSA system).
  • Accurately analyzes transactional account trends and patterns as well as identification documentation and CIP to efficiently document a conclusion upon completion of EDD reviews of high risk customers. Makes decision to keep high risk, lower risk or refer for account closure.
  • Provides updated information to the CDD/EDD Manager for updating/revising procedures for the handling of newly identified high-risk customers, to include the proper method to review such accounts and to report suspicious activity, document relationships and/or recommendation of account closure if deemed necessary.
  • Reviews reports in BAM or Alerts in BAM+ to determine if there are NGO (Non-government Organizations) or MSB (Money Services Businesses) unidentified in the BSA system. Adds tags and comments as needed.
  • Communicates with applicable bank personnel to obtain any further documentation and/or information necessary to complete the investigations or reviews of high risk accounts.
  • Stays up-to-date on MSB requirements for Louisiana, Mississippi and Texas as well as federal guidelines.
  • Tracks documentation required on all MSBs and directly work with Banking Center and Lending employees to resolve any exceptions.
  • Processes alerts in BAM+ that reflect any Privately-Owned ATM type transactions for accounts not tagged as PATM owners.
  • Evaluates transactional activity in accounts identified as PATM or MSB to determine any unusual patterns or lack of cash activity based on trends.
  • Adds tags and comments to new RDC (Remote Deposit Capture) accounts in BAM with risk rating assigned.
  • May be assigned alerts or cases in BAM+ for Red Flags or New Account scenarios and others as assigned to review and determine if the alert can be cleared or needs further investigation.
  • Maintains proficient knowledge of the rules and regulations, including but not limited to, the Bank Secrecy Act, USA Patriot Act, and OFAC as well as the bank’s policies and procedures.
  • Understands how to operate all systems and software programs used to obtain customer information, transaction history, and archive reports used to gather information for the BSA program.
• CTRs/CTR Exempt Reviews
  • Prepares and ensures proper completion of required Currency Transaction Reports (CTRs) for regulatory filing and submission to Financial Crime Enforcement Network (FinCEN) according to deadlines. Maintains records as required.
  • Ensures CTR filings are completed accurately, timely and meet regulatory requirements within the allowed timeframe of 15 calendar days.
  • Analyzes all CTRs for unusual and/or suspicious activity. Reports suspicious activity for further investigation via Alert or Case in BAM+. Documents all findings to the comments in the CTR Bank Use Only section.
  • Develops an understanding of the industry and AML related regulations as well as patterns of behavior that represents suspicious activity and stays up-to-date on changes in the industry.
  • Completes required annual reviews for all Phase II and applicable Phase I in the CTR Exemption processes, in addition to completing an analysis of possible exemptions. Assists with application preparation and e-filing of new exemptions.
  • Completes all job-related training in a timely manner and attends seminars or continuing education, as directed and monitor required continuing education credits.
  • Serves as a backup to the Systems Analyst for select actions (see duties listed in next section).
• Systems and Validations
  • Accesses Administration section of BAM+ to reset passwords and to activate or deactivate users.
  • Completes daily validation of non-validated transactions in BAM (on-line BSA system) for teller and wire transactions.
  • Completes daily review and validation for sale of cashier’s checks and gift cards. Monitors the sale of monetary instruments to ensure the BSA recordkeeping requirements are met.
  • Reports suspicious activity noted in validations for further investigation via Alert or Case in BAM+.
  • Operates all systems and software programs used to obtain customer information, transaction history, and archive reports used to gather information for the BSA program.
  • Processes foreign currency transactions and verifies daily entry of virtual vault transactions in BAM.
  • Reviews report in BAM to determine if currency exchanges take place on CTR exempt accounts. Refers any to the appropriate BSA Analyst that need an override for filing a CTR when required.
  • Reviews assigned manual reports from the BSA/AML system and reports findings to BSA Management as required.
  • Reviews completed CTRs and tracks errors. E-files CTRs via the FInCEN E-Filing System once any errors are corrected.
  • Reviews Unlink/Link report in CTR Manager to validate CTR preparation actions. Report any issues noted to the team manager for action.
  • Completes OFAC monitoring by importing OFAC list the same day as updated and reviewing transactions and reports of potential matches. Tracks updates to list in applicable bank systems each time the list updates.
  • Completes FinCEN 314(a) certifications by importing the list and reviewing transactions and reports of potential matches within designated timeframe. Updates records with certifications once processed and signed.
  • Communicates effectively with peers, front-line and management when requesting information or documentation and addressing concerns or findings.
  • Adheres to all designated time frames, manages workflow to the specified deadlines and completes responsibilities in a satisfactory manner.
  • Thoroughly documents findings by preparing reports in a manner that is clear and concise to BSA supervisors/managers, auditors and regulatory examiners.
  • Completes all job-related training in a timely manner and attends seminars or continuing education, as directed and monitor required continuing education credits.
  • Maintains proficient knowledge of the rules and regulations, including but not limited to, the Bank Secrecy Act, USA Patriot Act, and OFAC.
  • Maintains CTR exempt customers in IBS Insight for classification in Teller Insight.
  • Serves as backup to BSA Strategy and Systems Manager for select actions.

Supervisory Responsibilities

This job has no supervisory responsibilities.

Competencies - To perform the job successfully, an individual should demonstrate the following competencies:

Analytical and Design - Collects and researches data; Demonstrates attention to detail.

Problem Solving - Identifies and resolves problems in a timely manner; Gathers and analyzes information skillfully; Uses reason even when dealing with emotional or confidential topics.

Interpersonal Skills/Customer Service - Maintains confidentiality; Remains open to others' ideas and tries new things; Responds to requests for service and assistance; Meets commitments.

Oral and Written Communication - Speaks clearly and persuasively in positive or negative situations; Listens and gets clarification; Responds well to questions; Able to read and interpret written information.

Teamwork - Balances team and individual responsibilities; Contributes to building a positive team spirit; Puts success of team above own interests; Supports everyone's efforts to succeed.

Organizational Support - Follows policies and procedures; Completes administrative tasks correctly and on time; Supports organization's goals and values.

Judgment and Motivation - Exhibits sound and accurate judgment; Supports and explains reasoning for decisions; Includes appropriate people in decision-making process; Makes timely decisions.

Planning/Organizing - Prioritizes and plans work activities; Uses time efficiently.

Professionalism - Approaches others in a tactful manner; Reacts well under pressure; Treats others with respect and consideration regardless of their status or position.

Quality and Quantity – Demonstrates accuracy and thoroughness; Completes work in timely manner.

Adaptability - Adapts to changes in the work environment; Able to deal with frequent change, delays, or unexpected events.

Attendance/Punctuality and Dependability - Is consistently at work and on time; Ensures work responsibilities are covered when absent; Arrives at meetings and appointments on time; Follows instructions, responds to management direction; Takes responsibility for own actions; Commits to long hours of work when necessary to reach goals.

Qualifications To perform this job successfully, an individual must be able to perform each essential duty satisfactorily. The requirements listed below are representative of the knowledge, skill, and/or ability required. Reasonable accommodations may be made to enable individuals with disabilities to perform the essential functions.

Education and/or Experience

High school diploma or general education degree (GED) required; Bachelor's degree (B. A.) from four-year college or university preferred; one to three years prior banking experience required, prior BSA experience preferred.

Computer Skills

To perform this job successfully, an individual should have knowledge of the Internet, Outlook, Microsoft Word and Excel. Ability to learn bank-specific software such as MPC, IBS, ADP, etc. Ability to use basic office machines.

Other Skills

Maintains a solid working knowledge (functional, operational, and legal) of the rules and regulations, including but not limited to, the Bank Secrecy Act, USA Patriot Act, and OFAC as well as the bank’s policies and procedures. Understands how to operate all systems and software programs used to obtain customer information, transaction history, and archive reports used to gather information for BSA program.

Bank Culture/Customer Service Skills

Ability and judgment to interact and communicate appropriately with other employees, customers and supervisor. Ability to serve customers, both internal and external, (community/public) in a manner that will reflect superior customer relations and enhance the overall marketing effort of Origin Bank.

Physical Demands

While performing the duties of this job, the employee is frequently required to stand; walk; sit; use hands to finger, handle, or feel and talk or hear. The employee is occasionally required to reach with hands and arms; climb or balance and stoop, kneel, crouch, or crawl. The employee must frequently lift and/or move up to 10 pounds and occasionally lift and/or move up to 25 pounds. Specific vision abilities required by this job include close vision, distance vision and ability to adjust focus.

Work Environment

The noise level in the work environment is usually moderate.

This job description reflects management's assignment of essential functions. It does not prescribe or restrict the tasks that may be assigned. Origin Bank shall, in its discretion, modify or adjust the position to meet the Bank’s changing needs. This job description is not a contract and may be adjusted as deemed appropriate in the Bank’s sole discretion.

Origin Bank is an equal opportunity employer and we do not discriminate in hiring or employment on the basis of race, color, sex, age, marital or veteran status, non-job related disability, religion, national origin, genetic information or any other basis protected by law.