Financial Crime Compliance Officer
Accounting & Finance, Legal
SmartSuite for the Financial Crime Compliance Officer
The Financial Crime Compliance Officer, often the BSA/AML Officer, owns the program that prevents money laundering, sanctions breaches and terrorist financing: the risk assessment, customer due diligence standards, transaction monitoring, suspicious activity reporting and regulator engagement.
Reports to:
What you own
The Financial Crime Compliance Officer, often the BSA/AML Officer, owns the program that prevents money laundering, sanctions breaches and terrorist financing: the risk assessment, customer due diligence standards, transaction monitoring, suspicious activity reporting and regulator engagement.
- Maintain the enterprise financial crime risk assessment
- Set customer due diligence and enhanced due diligence standards
- Oversee transaction monitoring, alert handling and case investigation
- File suspicious activity reports and manage regulator engagement
- Operate sanctions screening and escalation
- Deliver AML training and independent testing coordination
- Report program effectiveness to the board
At a glance
The GRC processes this role owns, touches and depends on.
Owns
accountable for the process
Touches
contributes or approves
Depends on
consumes its output
How the GRC processes connect
Three lines of defence set the frame; the chain shows where each process hands off to the next. Colours follow the Financial Crime Compliance Officer: navy is owned, blue is touched, grey is depended on.
- First lineThe business and its control ownersRun the processes, own the controls, fix the issues
- Second lineRisk, compliance and the domain programmesSet the frameworks, assess, monitor and advise
- Third lineInternal auditIndependent assurance to the board and audit committee
Reporting lines
Who this role reports to, who reports to them, and the peers they work with most.
Reports to
Chief Compliance Officer
See the roleDirect reports
Works closely with
Fraud Risk Manager
See the roleRegulatory Affairs Manager
See the roleInternal Auditor
See the roleGeneral Counsel
See the roleCompliance Analyst
See the roleHow SmartSuite supports the Financial Crime Compliance Officer
The Financial Crime Compliance Officer owns the program against money laundering and sanctions breaches, and answers to the board, the examiners and FinCEN for a program that is risk-based, tested and documented. SmartSuite holds the risk assessment, the obligations, the cases and the findings in one record, so examination readiness is standing, not a project.
Run the AML and sanctions program you own
Customer due diligence and enhanced due diligence standards are policies with owners, review cycles and attestation, so the standard a front-line team applies is always the current approved version.
Compliance Management suitePotential sanctions matches escalate through a defined workflow with the reviewer, decision and rationale recorded, so an OFAC question about a release decision is answered from the record rather than from recollection.
Compliance Management suiteAML training requirements and completions are tracked by role, with reminders for the overdue, so the training element of the program is evidenced for the examiner without a separate return.
Compliance Management suiteWork with fraud, regulatory affairs, audit and counsel
The Internal Auditor's independent testing draws on the controls, evidence and case records you maintain in Compliance Assessments & Testing, so the test covers the program as it actually operates.
Compliance Management suiteWhere an alert concerns fraud as well as money laundering, the case links to the Fraud Risk Manager's investigation, so one record carries the evidence and both programs see the outcome.
Compliance Management suiteFindings from FFIEC examinations and regulator requests logged in Regulatory Inquiries become actions with owners and due dates, so the Regulatory Affairs Manager and you can show the examiner what has closed.
Compliance Management suiteReport effectiveness to the board and the regulator
The financial crime risk assessment carries KRIs with tolerance thresholds in Enterprise Risk Management (ERM), so a shift in exposure by product, geography or channel reaches you as an alert rather than at the annual refresh.
Risk Management suiteThe AI Assistant in a SmartDoc field drafts board-level updates and compliance narratives from case metrics, testing results and open findings, so the report to the Chief Compliance Officer starts from the data rather than a template.
Compliance Management suiteGranular permissions and activity logs keep SAR decisions and investigations visible only to those who need them, as SAR confidentiality requires, while the record stays complete for the examiner.
Compliance Management suiteRisk management. Holds the financial crime risk assessment as a scored register by product, customer type, geography and channel.
Compliance management. Maps AML and sanctions obligations to controls and tracks testing and evidence for examinations.
Issues and actions. Manages alerts, investigations and SAR decisions as cases with audit trails and restricted access.
Reporting. Reports program metrics, open cases and examination findings to the board and regulators.
Products this role uses most
Industry reference
The Bank Secrecy Act and FinCEN's rules (31 CFR Chapter X), as amended by the AML Act of 2020, define the program: a risk assessment, customer due diligence, transaction monitoring, suspicious activity reporting and independent testing. The FFIEC BSA/AML Examination Manual is the examiner's checklist; OFAC rules govern sanctions screening. The FATF Recommendations set the international baseline, implemented in the EU's AML package and the UK's Money Laundering Regulations.
The role is concentrated in banking, broker-dealers (FINRA Rule 3310), money services businesses, insurers and crypto-asset firms, with lighter duties for designated non-financial businesses such as real estate and legal services.
Related roles
Chief Compliance Officer
See the roleExplore Further
Guides and definitions from the GRC Knowledge Center and the What-is glossary, chosen for this role.
Frequently asked questions
The Financial Crime Compliance Officer, often the BSA/AML Officer, owns the program that prevents money laundering, sanctions breaches and terrorist financing: the enterprise financial crime risk assessment, customer due diligence and enhanced due diligence standards, oversight of transaction monitoring, alert handling and case investigation, suspicious activity reporting and regulator engagement, sanctions screening and escalation, AML training and the coordination of independent testing. They report program effectiveness to the board. The Bank Secrecy Act, FinCEN's rules and the FFIEC examination manual define what that program must contain.
Enterprise Risk Management (ERM) holds the financial crime risk assessment as a scored register by product, customer type, geography and channel, so the inherent and residual risk for each dimension is recorded with its rationale rather than in an annual document. When a new product launches or a geography changes, the affected entries are updated and the assessment stays current between the annual refreshes examiners expect. The Fraud Risk Manager maintains the fraud entries in the same register, so overlapping schemes are visible.
SmartSuite maps AML and sanctions obligations to controls and tracks the testing and evidence for examinations, with the obligations held in Control Framework & Regulatory Libraries and the tests run in Compliance Assessments & Testing. The Financial Crime Compliance Officer can show an examiner the control that satisfies each FinCEN, OFAC or FINRA Rule 3310 obligation, when it was last tested and the evidence. The Internal Auditor's independent testing draws on the same records, which is what the examination manual expects.
Issues Management holds escalated alerts, investigations and SAR decisions as records with owners, audit trails and role-based access, so each escalated alert becomes a record with its investigation steps, the decision to file or not file and the reasoning, visible only to the team assigned. The Compliance Analyst works the cases and the Financial Crime Compliance Officer reviews decisions from the same record. SmartSuite is the case and program record around your monitoring and screening systems rather than a replacement for them.
SmartSuite reports program metrics, open cases and examination findings to the board and regulators from the register, the control tests and the case records, so the Chief Compliance Officer and the board see alert and case volumes, time to decision, testing status and open examination findings from the live program. Regulatory Inquiries holds examiner requests and responses, with the Regulatory Affairs Manager and the General Counsel working in the same record. Findings from an examination are tracked to remediation with owners.
Load the current risk assessment by product, customer type, geography and channel, the obligation set for the regimes you are examined under and the control list with its testing calendar; open cases and examination findings can be loaded or started fresh. The first examination cycle run from SmartSuite gives the examiner the traceable record they look for. The Fraud Risk Manager, the Internal Auditor and the Compliance Analyst work in the same records, so independent testing and investigations draw on one source.