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AML Audit Executive

Location Plano, Texas | San Antonio, Texas Secondary Locations Plano,Texas;San Antonio,Texas; Job ID R0034796 Date posted Jun. 20, 2019 Apply Now

Purpose of Job

The Assistant Vice President, AML Officer, Audit Services leads the development of a comprehensive Bank Secrecy Act (BSA), Anti-Money Laundering (AML) internal audit program across the enterprise. Provides the Finance and Audit Committees of the USAA, FSB and USB Board of Directors, the CEO, and members of USAA management with independent, objective assurance services regarding the effectiveness and efficiency of the AML program governance, risk management, compliance and control processes.

Job Requirements

Managerial Responsibilities

  • Leads design and execution of USAA’s BSA/AML audit program and plan, considering USAA’s business strategy and complex regulations and regulatory heightened expectations, including how they apply in a matrixed business environment. 
  • Role models USAA’s mission, core values, culture and desired behaviours – including a culture of risk awareness around BSA/AML and accountability.
  • Develops talent and builds high performing teams to deliver high quality results and value-added services – including the identification, development and retention of talent with requisite audit and BSA/AML capabilities as well as providing leadership and overseeing performance and talent management activities.
  • Supervises and drives operational planning of the BSA/AML audit team – including core business processes and technologies.
  • Holds self and others accountable to meet commitments by setting and clearly communicating expectations and roles and responsibilities relative to BSA/AML audits.

Technical and Risk Responsibilities           

  • Manages and directs all aspects of the internal audit BSA/AML program, including overseeing audit fieldwork on all AML audit engagements, developing a risk-based annual audit plan covering the BSA/AML program, and an audit approach that mirrors current, professional internal audit standards and regulatory expectations.
  • Re-prioritizes the BSA/AML/AML audit plan as necessary based upon changes in risk. Assures appropriate staffing (internal or external) is available to execute the plan.
  • Monitors major change initiatives and provides advisory feedback and support to the BSA/AML Compliance team on progress of overall initiatives when applicable
  • Oversees special audits from management as appropriate and special reviews, investigations, monitoring activities, and ensures engagements are completed objectively and in accordance with USAA and industry audit standards.
  • Monitors and reports on the progress of management follow-up to audit observations.
  • Provides support to the Chief Audit Executive and reports periodically on the activities of the internal audit AML program to the USAA, FSB and USB Finance and Audit Committees, the Chief Executive Officer, Executive Management and other subsidiary boards as appropriate.
  • Identifies control weaknesses and opportunities for improvement in the current operating environment and gives recommendations for corrective action.
  • Provides technical and strategic direction to audits that are sensitive, complex and/ or comprehensive in nature.
  • Stays abreast of and maintains a current knowledge of the direction of USAA through discussions with corporate officers and attendance at various management meetings, conferences, and Board of Directors meetings to integrate current risks into the audit plan.
  • Stays engaged with management level governance committees that address BSA/AML & OFAC, offering credible and effective challenge as needed during committee meetings.
  • Establishes and develops relevant, critical benchmarking information to maintain an efficient and effective BSA/AML audit program that maintains a forward-looking approach.
  • Creates and manages both short & long-term strategies adjusting audit approach and plans accordingly to align with changes related to new products and services, organizational structure, Bank’s risk profile, and/or strategic initiatives.
  • Provides independent assurance to the board of directors and senior management on the effectiveness of the design, implementation and execution of the banks’ BSA/AML related business processes and related risk management framework (including risk profile, risk appetite, and compliance practices).
  • Delivers and communicates audit results, including material issues, root causes and recommendations, to executive management and Risk committees, identifying and escalating to the Board’s audit committee’s significant control weaknesses and strengths related to compliance with regulations, polices, standards and procedures.
  • Interacts effectively with all key Governance Committees established by USAA, FSB and USB.

Governance Committees

Interacts with or participates in enterprise governance committees, such as:

  • USAA Financial Crimes Compliance Committee

Education

  • Bachelor’s degree is required.
  • Advanced degree such as MBA or Finance is preferred.

Experience

  • A minimum of 10 years of experience in technical discipline (e.g. Audit, AML compliance) with a proven track record leading comparable operations and programs (such as auditing AML programs/issues and BSA/AML/OFAC program) is required.
  • A minimum of 6 years of people leadership experience in building, managing and/or developing high-performing teams is required.
  • A minimum of 6 years of relevant experience in a large financial institution ($100 billion +), including 5+ years post-Dodd Frank, within an audit department or major control function, with experience handling regulatory programs relating to money laundering, is preferred.

Regulatory Understanding*

Demonstrated understanding of the full spectrum of regulatory actions, including examinations and other supervisory engagement and processes, such as:

  • Dodd-Frank Act
  • Home Owners’ Loan Act
  • Fair Lending laws
  • Texas Insurance Code
  • New York Insurance Law
  • Securities and Exchange Commission Statutes, including the 1933 Securities Act and the 1934 Exchange Act

Federal regulations and supervisory guidance:

  • 12 CFR Part 238 (Regulation LL)
  • 12 CFR Part 252 (Regulation YY)
  • 12 CFR Part 223 (Regulation W)
  • 12 CFR Part 30, including Appendices A through E
  • 12 CFR 9 - Bank Fiduciary Activities
  • 12 CFR 25 -- Community Reinvestment Act
  • 12 CFR Part 46 (Annual Stress Test)

Federal Reserve Supervisory Guidance Documents: 

  • SR 12-17 (Consolidated Supervision Framework for Large Financial Institutions);
  • SR 08-08 (Compliance Risk Management Programs);
  • SR 14-9 (Incorporation of Federal Reserve Policies into the Savings and Loan Holding Company Supervision Program and related applicable guidance);
  • Bank Holding Company Examination Manual;
  • Federal Reserve proposals concerning Board effectiveness and core principles of effective senior management, management of business lines, and independent risk management and controls
  • OCC Supervisory Guidance Documents:  Large Bank Supervision Handbook; Corporate and Risk Governance Handbook; and key OCC bulletins (Model Risk Governance; Model Risk Management; New Products and Services Risk Management; Third Party Risk Management)
  • FFIEC: BSA/AML Manual; IT/Cyber Handbooks
  • CFPB: Consumer Protection Regulations; UDAAP

Certifications

Industry certification such as Certified Internal Auditor (CIA) or Certified Anti-Money Laundering Specialist (CAMS) certification is preferred.

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