Due Diligence Advisory

Column’s Financial Crime Compliance (“FCC”) team has primary responsibility for the execution of the firm’s enterprise-wide Anti-Money Laundering (“AML”), anti-bribery, and government sanctions compliance programs. Its remit includes performing enhanced due diligence and government sanctions screening, as well as surveillance and investigations designed to identify potential terrorist financing, money laundering, bribery, market abuse, and other suspicious activity.

The Due Diligence Advisory position plays a crucial role in safeguarding Column from financial crimes and ensuring compliance with AML and Sanctions regulations. This position will oversee the strategy and execution of the Bank’s “Know Your Customer” (KYC) program, inclusive of customer identification and verification, due diligence, and enhanced due diligence activities. The scope includes working closely with stakeholders across Column’s Compliance, Operations, Third Party Risk Management, and Business teams to ensure effective and comprehensive due diligence is conducted across products, onboarding flows, and customer types. This role will also be responsible for the oversight and execution of upfront and periodic enhanced due diligence for high and moderate risk customers.

This role reports directly to the Bank’s BSA Officer. While an in-person presence in the Bank’s Presidio-based office is strongly preferred, this role is open to remote applicants with the expectation of periodic travel.

What you’ll do:

Customer Identification and Verification:

• Further enhance the Bank’s Customer Identification and Verification processes and controls for retail and commercial banking customers, including fintech relationships
• In coordination with FCC and other first and second line stakeholders, review and address  any manual reviews generated by onboarding tools
• Work with FCC and Engineering stakeholders to enhance the Bank’s automated Customer Identification and Verification capabilities
• Maintain Customer Identification and Verification procedures and Account Opening Procedures in coordination with the BSA Officer

Customer Due Diligence/Enhanced Due Diligence:

• Further enhance business and FCC-led due diligence processes and controls for retail and commercial banking customers, including fintech relationships
• Develop standards regarding, and lead the FCC oversight of, due diligence collection, review, and assessment; providing guidance and supporting review decision where needed
• Perform onboarding Enhanced Due Diligence (“EDD”) collection for applicable customers including the completion of Onboarding High Risk EDD Reviews and ongoing Periodic Reviews

Collaboration and Communication:

• Collaborate with other departments, including business units, Compliance, Legal, and Third Party Risk Management, to integrate Due Diligence and Enhanced Due Diligence efforts into the overall compliance framework
• Communicate effectively with external law enforcement agencies, regulators, and other relevant entities as needed
• Work collaboratively with BSA Officer on overall KYC program design and execution

Continuous Improvement:

• Stay up-to-date with evolving AML laws, regulations, and industry best practices
• Identify opportunities for process improvement and implement enhancements to the KYC program

Reporting and Governance:

• Assist the BSA Officer with KRI/KPI reporting related to Due Diligence and Enhanced Due Diligence operations
• Develop and communicate ongoing customer risk information to internal and external stakeholders
• Highlight key trends, risks, issues, and opportunities for enhancements for the KYC program

   

What you’ll need to be successful:

• Bachelor’s degree in finance, business, or a related field; professional certification (e.g., CAMS) is preferred
• 7+ years of prior experience in Financial Crimes Compliance, preferably with experience at a financial institution
• Understanding of Financial Crime, AML and terrorist financing trends and typologies
• Ability to determine and communicate FCC requirements to business, operations, and engineering teams
• Expert-level understanding and execution experience related to Customer Identification and Verification requirements, especially as it relates to legal entities with complex ownership structures and/or customers with foreign operations
• Expert-level understanding and execution experience related to the AML due diligence and enhanced due diligence activities associated with opening commercial bank accounts and FBO accounts, especially as it relates to third party senders, non-bank financial institutions, and/or similar third-party money transmission use cases.
• In-depth knowledge of AML laws and regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and OFAC requirements
• Strong analytical and problem-solving skills
• Excellent communication and interpersonal skills
• Proficiency in AML software and data analysis tools
• Attention to detail and a commitment to accuracy

   

What you’ll get from us:

• Flexible PTO
• Competitive medical, dental, and vision plans (including options 100% subsidized by Column)
• FSA + HSA options
• 401(k) plan
• Commuter benefits
• Sponsored lunches and dinners in our SF office