BSA/AML Compliance Officer

About OliBank

OliBank's mission is to make managing finances as easy as possible. Our vision is an evenly distributed, global, digital-first financial system that levels the playing field.

Our values: Sense of Urgency, Customer Obsession, Pride in Craftsmanship.

How we work:

• Culture eats strategy - everyone owns it, everyone can be held accountable to it.
• Culture of ownership - keep the bar high, own decisions, correct and learn.
• Long-term results over short-term wins - with urgency.
• Build great systems, make the complex simple, use forcing functions.
• Obsess over the details (culture, customers, product, process, data).
• Bias for action, be bold, disagree-and-commit, end with the positive - and mistakes have consequences. There is always room for improvement.

Compliance at OliBank is not a back office. It is how we earn the right to move money globally. This role owns that.

The role Designated BSA/AML Officer. You own a risk-based BSA/AML/OFAC compliance program that satisfies FinCEN, OFAC, and OCIF expectations for a FinCEN-registered MSB operating with a Puerto Rico IFE - including SAR decisioning authority, FinCEN 314(a) handling, sanctions screening governance, and Board reporting.

Main responsibilities

BSA/AML program ownership

• Own and maintain the risk-based BSA/AML compliance program (CIP/KYB/KYC, beneficial ownership, EDD, ongoing monitoring, recordkeeping) across the MSB and bank programs, with clear capacity-split documentation for each decision.
• Serve as designated BSA Officer with authority for SAR determinations, SAR filing clocks (31 CFR 1020.320), continuing-activity reviews, confidentiality/no-tipping, and 314(a) searches (14-day window, no-hit logs, no disclosure to subjects).
• Report directly to the Board on program health, trends, and deficiencies - trends and metrics, never case-file detail in minutes. Sanctions & screening
• Govern sanctions screening: direct OFAC SLS ingestion/reconciliation, ITA CSL / EU / UK sources, OFAC 50 Percent Rule ownership handling, pre-submission beneficiary screening, fuzzy-match disposition, and fail-closed behavior on screening outages.
• Own OFAC block/reject handling (31 CFR 501.603/601.604, 10-business-day reporting) - confirmed matches block; auto-return/retry only after false-positive disposition. Client lifecycle & transactions
• Evaluate onboarding, EDD triggers (high-risk jurisdiction, complex ownership, volume, PEP/sanctions), and transaction activity for compliance risk.
• Proactively audit processes, KYB artifacts, monitoring alerts, and CIS risk-scoring dispositions; document findings, remediations, and residual risk.
• Own vendor and counterparty compliance touchpoints: compliance sign-off on vendor reviews where BSA/AML screening or monitoring is implicated.

Controls, training, culture

• Build simple, systemic internal controls with forcing functions - not one-off customizations. No "100% guarantee" language; design for reasonable, risk-based, auditable compliance.
• Own the training program (staff, engineering/CIS, Board orientation, alternate/interim BSA coverage).
• Manage independent testing / audit remediation, examiner requests (OCIF, IRS BSA exam for MSB), and the residual-risk register.

Experience required

• 3+ years BSA/AML compliance experience in a regulated financial institution; direct experience with a Puerto Rico IFE / OCIF examination cycle required.
• Hands-on SAR lifecycle: investigation, determination memos, filing clocks, continuing activity, confidentiality. Must be able to evidence SAR decisioning authority.
• Working knowledge of BSA recordkeeping, funds-transfer recordkeeping (§1010.410), FinCEN 314(a), OFAC administration, and MSB obligations (31 CFR Part 1022 vs. bank Part 1020/CIP differences).
• Experience with transaction monitoring / risk-scoring systems, KYB/KYC vendors, and audit of alert dispositions (false-positive rationale discipline).
• Risk management and/or financial-crimes audit experience (2+ years).
• Strong research, writing, and Board-level communication skills. Fluent English required; Spanish a strong plus (OCIF/market reality).
• Integrity, independence of judgment, and willingness to veto - disagree-and-commit cuts both ways; the BSA decision is yours. Strongly preferred
• Professional certification: CAMS, CGSS, CRCM, or equivalent.
• Stablecoin / cross-border payments experience.
• Data-protection literacy (GDPR concepts); privacy-framework experience is a plus, not core.

Education

• University degree in law, finance, business administration, or related field. JD or advanced degree a plus, not required.

Location: Must be located in or self-relocating to Puerto Rico