BSA/AML/OFAC Special Investigations Analyst

Summary of Position

The BSA/AML/OFAC Special Investigation Investigator is responsible for conducting first level anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions investigations. This role focuses specifically on processing and investigating FinCEN 314(b) information-sharing requests, performing high-risk wire transfer reviews, and executing targeted special monitoring reviews. The Analyst evaluates transactional activity for suspicious patterns, ensures compliance with Bank Secrecy Act (BSA), USA PATRIOT Act, and OFAC regulations, and prepares comprehensive investigative recommendations. 

Essential Functions and Duties

FinCEN 314(b) Reviews & Investigations

• Manage the end-to-end FinCEN 314(b) information-sharing process, including processing incoming requests from peer institutions and initiating outgoing requests.
• Verify institution eligibility and secure participation status on the FinCEN 314(b) list prior to sharing sensitive customer/transactional data.
• Conduct joint or cross-institutional investigations into suspected money laundering or terrorist financing schemes based on 314(b) exchanges.
• Document findings in a clear, audit-ready manner and determine whether exchange outcomes warrant internal account escalation, special monitoring, or Investigations.
• Maintain complete, confidential, and compliant records of all 314(b) communications in accordance with statutory retention mandates.

Wire Investigations & OFAC Screening

• Review and analyze post-transaction wire alerts generated by received SWIFT/FED wire Investigations 
• Investigate wire originators, beneficiaries, intermediaries, and payment details for potential OFAC sanctions matches, red flags, or complex layering schemes.
• Perform deep-dive reviews on high-risk wire activity, including international wire transfers, funds transfers involving high-risk jurisdictions, shell companies, or uncharacteristic transaction volumes.
• Coordinate with internal business lines (e.g., Wire Room, International Banking, Branches, Corporate Lending) to gather supporting documentation, invoice details, and business rationales for suspicious wire flows.

Special Monitoring & High-Risk Reviews

• Conduct targeted, periodic, and ad-hoc special monitoring reviews on customer accounts flagged for elevated risk, negative news, internal referrals, or regulatory inquiries.
• Analyze complex transactional datasets to identify emerging financial crime topologies, such as funnel accounts, trade-based money laundering (TBML), human trafficking, or structured deposits/withdrawals.
• Perform holistic customer due diligence (CDD) and enhanced due diligence (EDD) reviews in conjunction with special monitoring tasks.
• Prepare detailed narrative reports that synthesize transaction history, counterparty relationships, line-of-business context, and external intelligence.

Compliance Support

• Assist in maintaining logs, tracking metrics, and preparing dashboard reports on 314(b) inquiry volumes, wire alerts, and special monitoring outcomes for senior management.
• Participate in annual BSA/AML/OFAC audits and regulatory examinations by providing requested case files, workflow documentation, and sampling data.
• Stay current on regulatory updates, FinCEN advisories, OFAC sanctions lists changes, and emerging money laundering trends

Qualifications Requirements

• Education: High School diploma or equivalent experience.
• Experience: Three (3) to Five (5) years of experience in in BSA/AML compliance, financial crime investigations, or sanctions screening within a financial institution.
• In-depth understanding of BSA/AML regulations, the USA PATRIOT Act (specifically Sections 314(a) and 314(b)), and OFAC sanctions programs.
• Demonstrated experience in wire transfer analysis, payment messaging formats (SWIFT, Fedwire), and counterparty risk evaluation.
• Advance computer skills including but not limited to proficiency in Microsoft Office (Word, Excel, Power Point, etc.)
• Must be bilingual in both English and Spanish. Ability to fluently speak, understand, read and write both languages.
• Strong verbal and written communication skills, ability to communicate at all levels of the organization.
• Strong attention to detail and accuracy.
• Ability to multi-task, with strong organization, time-management and prioritizing skills. 
• Strong customer service skills, ensuring satisfaction of internal and external customers. 
• Problem solving and analytical skills in order to identify problems.
• Advance knowledge of related State and Federal banking compliance regulations and operational policies. 
• Knowledge of related state and federal banking BSA/ AML regulations.
• Ability to understand and comprehend instructions, procedures and policies ensuring compliance with the Bank’s policies and procedures.