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Corporate Compliance Manager - Financial Crimes Governance in Houston, TX at KeyBank

Date Posted: 4/6/2021

Job Snapshot

  • Employee Type:
  • Location:
    Houston, TX
  • Date Posted:

Job Description

*This position can be located anywhere

The Corporate Compliance Manager role is a manager role reporting to the bank’s Financial Crimes Governance Financial Intelligence Director. The Compliance Manager maintains subject matter expertise of BSA/AML and Customer Due Diligence (CDD) customer risks and mitigation tactics related to merchant acquiring, commercial payment enterprises, commercial real estate, and higher-risk client types. This role will support a number of high-growth business functions and requires the ability to apply expertise in support of the commercial interests while effectively managing BSA/AML risk.

The Compliance Manager should have practical experience with payments businesses operating in a regulated financial institution regime, in particular direct and indirect merchant acquiring. The Compliance Manager should also have a strong working knowledge of risks associated with the following high-risk customer types: foreign and domestic Sovereign Wealth Funds (SWFs), Private Investment Companies (PICs), and Pooled Investment Vehicles (PIVs), especially in the commercial real estate space. Requires solid working knowledge of BSA/AML, OFAC/Sanctions, and CDD Beneficial Ownership regulations and regulatory expectations for these areas of focus.

The Compliance Manager is responsible for assisting with the development of operating requirements for new payments businesses, including indirect merchant acquiring (e.g., Independent Sales Organization, Payment Facilitator model), and support in the oversight of risk-based CDD with regard to AML high risk customers that may be required to maintain an AML Program, as well as evaluation and making decisions regarding relationship retention or exit of such customers. The Compliance Manager will also assist with the onboarding and ongoing CDD of complex commercial real estate investors. The Compliance Manager may also be called upon to represent BSA/AML KYC and OFAC/Sanctions interests and needs in other new customer, product/service, and/or vendor initiatives.

The successful candidate possesses strong analytical, communication, sound judgment, and leadership skills and will be called upon to lead various initiatives that enhance upon the bank’s BSA/AML and OFAC/Sanctions compliance program. The successful candidate will possess the ability to work independently, be a thought leader, execute upon strategies that mitigate BSA/AML and OFAC/Sanctions risks to the bank and quickly recognize issues that require escalation to Senior Management.

Essential Job Functions:
The Corporate Compliance Manager will be responsible for oversight and providing guidance on the following:

Solid knowledge of BSA/AML and OFAC/Sanctions banking regulations, regulatory expectations, and risks, especially as they pertain to payment systems, merchant acquiring, and complex commercial real estate investors such as foreign and domestic SWFs, PICs, and PIVs, as well as Politically Exposed Persons (PEPs).
Review of new or changing regulations impacting the bank that involve payment systems, merchant acquiring, foreign and domestic SWFs, PICs, PIVs, and PEPs.
Work closely with business partners to develop BSA/AML and OFAC/Sanctions requirements for new payments businesses, including indirect merchant acquiring
Apply knowledge of bankcard payment operator network rules, standards, and practices, particularly involving prohibited and high-risk merchant categories and transactions to develop and maintain operating requirements.
Conduct analysis and investigation of foreign and domestic SWFs, PICs, and PIVs, and related PEPs, as part of new or on-going client relationships.
Serves as source of subject matter compliance expertise with regard to payment systems, merchant acquiring, foreign and domestic SWFs, PICs, and PIVs, and participating in resolving compliance issues and promoting effective and consistent management of compliance risks.
Help ensure lines of communication between the departments and business units/entities executing compliance requirements remain open and aligned with processes to gain efficiencies, avoid unnecessary redundancies, and coincide with business and customer risk profiles.
Work closely with AML and OFAC/Sanctions operations support areas to ensure compliance with BSA/AML and OFAC/Sanctions requirements including onboarding, enhanced due diligence, and investigations reviews.
Drive or participate as stakeholder or team member on projects/initiatives as warranted by scope.
Participate in new business initiatives, new product development, and product analysis.
Effectively and professionally interact with internal audit and/or regulatory agency personnel including answering examination information requests, addressing examination findings, and discussing compliance processes and policies.
Promote a proactive compliance culture, delivering advice and guidance to the business/support functions.

Required Qualifications:
At least 5 – 7 years of BSA/AML regulatory, compliance, audit, or comparable BSA/AML experience
One or more of the following:Experience working with direct and/or indirect merchant acquiring within a regulated financial institution regime and knowledge of related bankcard payment operator network rules, standards, and practices
Experience with Independent Sales Organizations, Payment Facilitators, or Third Party Payment Processors is desired
Experience in commercial real estate, working with foreign and domestic SWFs, PICs, and PIVs (and/or similar complex business structures), including conducting corporate due diligence

Working knowledge of commercial/institutional payment systems desired
Geopolitical risk and PEP experience desired
A Bachelor’s Degree is required, with advanced degree(s) of JD or MBA desired
CAMS certification desired
Excellent analytical and investigative skills
Excellent writing skills and the ability to succinctly convey information to senior business and compliance management
Exceptional ability to manage or otherwise support multiple programs in a fast-paced environment with changing priorities and significant time pressures
Exceptional ability to work across departments and business units/entities to ensure compliance requirements are understood and met
Strong attention to detail
High ethical standards.


KeyCorp is an Equal Opportunity and Affirmative Action Employer committed to engaging a diverse workforce and sustaining an inclusive culture. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or veteran status.



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