Position:                                   Deputy Chief Compliance Officer

Department:                          Legal – NY Office

Reports To:                             Chief Compliance Officer  

Compensation Range:     $200K to $225K w/ Discretionary Bonus     

Job Summary:

In conjunction with the Chief Compliance Officer and the Chief Legal Officer, the Deputy Chief Compliance Officer is responsible for developing, implementing and administering all aspects of the Bank’s Compliance Program, including compliance with the Bank Secrecy Act (BSA), anti-money laundering (AML) laws, Office of Foreign Assets Control (OFAC) programs and related state and federal requirements including New York’s Part 504.  In addition to BSA/AML and OFAC requirements, the company’s compliance program establishes compliance in areas including, but not limited to, Community Reinvestment Act, fair lending, mortgage lending and servicing, affiliate transactions, fintech and digital financial services, third-party technology and service-provider oversight, payment activities and other laws and regulations relevant to this diverse private banking institution.

Job Specific Responsibilities and Duties:

• Working with the Chief Compliance Officer, develop, implement and administer all aspects of the Bank’s Compliance Program.
• Write, review and update as necessary BSA, AML, OFAC, and KYC related policies, programs and procedures.
• Maintain proficient knowledge of the rules and regulations on Bank Secrecy Act, USA Patriot Act and OFAC, as well as other legal and regulatory compliance requirements applicable to the Bank’s diverse business units.
• Oversee the Bank’s fair lending, CRA, mortgage and consumer compliance programs.
• Provide compliance oversight and guidance with respect to fintech products, digital banking services, payment activities, and emerging financial technologies, including assessing applicable regulatory requirements and associated compliance risks.
• Partner with business, technology, information security, and risk teams to assess compliance risks associated with fintech platforms, third-party service providers, APIs, payment processors, and other technology-enabled financial services.
• Oversee the Bank’s Regulation O and W compliance programs.
• Oversee the annual review of Bank and business unit policies.
• Oversee the annual bank-wide Risk Assessment process, Red Flags process and Customer Risk Ratings reviews and updates.
• Oversee organizational projects necessary to ensure compliance with relevant laws and regulations by the Federal Deposit Insurance Corporation, Federal Reserve, and New York State Department of Financial Services.
• Oversee review of activity associated with SAR filings
• Work with Internal Audit on business compliance.
• Ensure appropriate training for all Compliance personnel and bank-wide personnel.
• Assure organizational compliance with applicable laws and regulations
• Coordinate BSA/AML and Compliance audits and exams, responses to auditors and regulatory examiners and ensure deficiencies are corrected.
• Ensure compliance with all applicable reporting and record keeping requirements and timely distribution of materials and publications.
• In conjunction with the Chief Legal Officer and the Chief Compliance Officer, assist in reporting to the Governance and Compliance Committee of the Board of Directors when and where appropriate.

Qualifications:

• JD required, and 10 years’ experience in legal/compliance matters in the banking industry, or equivalent training and experience.  Private practice experience preferred though not required.  Prior service in a regulatory agency a plus, though not required.    CAMS certification a plus.
• Experience advising on compliance considerations for fintech, digital banking, payments, financial technology platforms, or other technology-enabled financial products and services is preferred.

Additional Skills:

• Execute tasks with accuracy and attention to detail.
• Perform responsibilities with honesty and integrity.
• Willingness to learn and be challenged.
• Ability to work independently but also to consult when needed with senior management.
• Supervise staff and oversee compliance activities of bank-wide program.
• Clearly establish policies and guidelines for regulatory compliance and to oversee bank-wide system of compliance relevant to varied business units.

The job description outlined above is considered a core list of job duties/requirements.  This document should not be considered a complete or comprehensive list.  The incumbent assigned to this position is required to perform the duties listed above.  The incumbent is also expected to adapt to changes and/or additions as needed.  Nothing contained within this document is intended or shall be construed to create or constitute a contract of employment between any employee or group of employees and Emigrant Bank and its Subsidiaries.  Emigrant Bank and its Subsidiaries retains and reserves any and all rights to change, modify, amend, add to or delete from any section of this document as it deems, in its judgment, to be proper.