Director, Financial Crimes Compliance

About the role

This position is central to upholding Upstart Bank's financial crimes compliance framework. You will be instrumental in developing and maintaining robust compliance solutions within a dynamic fintech environment, fostering strong relationships across the organization.

Key facts

What you'll do

• Establish and manage the company-wide Bank Secrecy Act (BSA), Anti-Money Laundering (AML), and Office of Foreign Assets Control (OFAC) compliance program, ensuring adherence to regulations, emerging risks, and the company's risk tolerance.
• Conduct enterprise-wide BSA/AML and sanctions risk evaluations, identify new threats, and implement risk-based controls, monitoring systems, and governance structures to reduce financial crime exposure.
• Deliver regular updates to the Board of Directors, senior leadership, and risk committees, detailing risk assessment findings, program effectiveness, key risk indicators, regulatory changes, and remediation status.
• Oversee the framework for Customer Identification Program (CIP), Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD), including customer risk categorization and ongoing monitoring.
• Supervise the review and management of high-risk customer accounts, covering onboarding, periodic reviews, escalation procedures, and recommendations for account closure.
• Provide senior guidance and oversight for complex investigations involving unusual activity, suspicious activity reporting (SAR), and other regulatory reporting obligations.
• Act as the primary liaison for regulatory reviews, independent audits, and compliance assessments concerning BSA/AML and sanctions compliance, ensuring prompt and effective resolution of identified issues.
• Collaborate with Product, Engineering, Operations, Legal, and Risk teams to create scalable financial crime controls for new offerings, including consumer deposit and lending products.
• Track regulatory changes and provide expert advice on BSA, AML, sanctions, fraud, and other financial crime compliance requirements relevant to Upstart's operations.

Requirements

• Bachelor's degree in Business, Finance, Accounting, Criminal Justice, Law, or a related field.
• A minimum of 10 years of experience managing BSA/AML compliance programs within a bank, credit union, fintech, or similar regulated financial entity.
• Comprehensive understanding of the Bank Secrecy Act (BSA), USA PATRIOT Act, OFAC sanctions regulations, FinCEN directives, KYC, CIP, CDD, EDD, and SAR requirements.
• Proven experience conducting BSA/AML/OFAC risk assessments and utilizing the outcomes to build, enhance, and manage BSA/AML compliance programs for consumer deposit and lending products.
• Experience managing high-risk customer programs, customer risk rating models, enhanced due diligence processes, and decisions regarding customer relationship terminations.
• Demonstrated ability to lead regulatory examinations, independent audits, and remediation efforts related to BSA/AML and sanctions compliance.
• Experience presenting financial crime compliance matters, risk assessments, and program metrics to executive leadership, risk committees, and Boards of Directors.
• Familiarity with consumer banking regulations pertinent to deposit and lending products.

Nice to have

• CAMS (Certified Anti-Money Laundering Specialist), CAFP (Certified AML and Fraud Professional), CRCM, or a comparable compliance certification.
• Experience serving as a BSA Officer, Deputy BSA Officer, or in a senior financial crimes compliance leadership role at a highly regulated financial institution.
• Experience developing and scaling AML transaction monitoring, sanctions screening, customer risk scoring, and implementing case management systems.
• Experience utilizing AI-driven solutions to enhance and automate BSA program activities.
• Knowledge of digital banking, fintech, embedded finance, or marketplace lending business models.
• Experience implementing technology-based compliance solutions, automated controls, and risk monitoring frameworks.
• Direct experience working with federal and state banking regulators, including OCC, FDIC, Federal Reserve, CFPB, FinCEN, or state banking agencies.
• Familiarity with fraud risk management frameworks and the interplay between fraud and AML compliance programs.

Skills & tools

• BSA/AML/OFAC compliance frameworks
• Risk assessment methodologies
• Regulatory reporting
• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
• Suspicious Activity Reporting (SAR)
• Consumer deposit and lending product compliance

Practical notes

• The team operates within East/West coast time zones.
• While the company is digital-first, regular in-person collaboration sessions (onsites) are expected 1-2 times per quarter, lasting 2-4 consecutive days.
• Anticipated Base Salary Range: $201,200 - $278,500 USD. Actual salary will vary based on geographic location, skills, experience, and education.
• Compensation includes target bonuses, equity, and comprehensive benefits.
• Benefits include medical, dental, vision, 401k with company match, paid time off, and family leave.
• Upstart is an Equal Opportunity Employer. For accommodation requests, email candidate_accommodations@upstart.com.