Responsibilities
- Design and execute a risk-based QA program covering key 2LoD Financial Crimes activities, including:
- Oversight and challenge of Transaction Monitoring (TM) alerts and dispositions
- Review and challenge of Suspicious Activity Report (SAR) escalation decisions
- Customer Risk Rating (CRR) methodology application and governance outputs
- Oversight of Customer Due Diligence (CDD) / Enhanced Due Diligence (EDD) reviews
- Sanctions advisory, escalation, and disposition decisions
- Assess whether 2LoD outputs demonstrate:
- Effective challenge and appropriate escalation
- Consistent interpretation of policies and regulatory expectations
- Adequate documentation, rationale, and audit trail
- Perform detailed QA reviews of 2LoD casework, memos, and decisions to evaluate:
- Accuracy and completeness
- Appropriateness of risk-based judgments
- Alignment with internal standards and regulatory expectations
- Evaluate the quality of 2LoD oversight, including whether issues are appropriately identified, escalated, and resolved
- Identify inconsistencies in decision-making and gaps in challenge or governance
- Conduct horizontal reviews across 2LoD outputs to identify:
- Systemic weaknesses in oversight practices
- Trends in ineffective challenge or missed escalation opportunities
- Inconsistencies in policy interpretation
- Develop insights into emerging risks and control blind spots within 2LoD
- Develop and maintain QA methodologies specific to 2LoD activities, including:
- Test scripts tailored to oversight and challenge functions
- Defect taxonomy focused on governance, escalation, and decision quality
- Scoring frameworks to assess effectiveness of 2LoD outputs
- Define sampling strategies based on risk, complexity, and materiality of 2LoD decisions
- Ensure clear differentiation between 1LoD execution errors and 2LoD oversight deficiencies
- Document QA findings with clear articulation of:
- Gaps in 2LoD oversight, challenge, or governance
- Root cause and impact on risk management effectiveness
- Assign severity ratings based on risk exposure and regulatory implications
- Produce management reporting and dashboards highlighting:
- QA results and trends
- Thematic issues and repeat findings
- Opportunities for strengthening 2LoD practices
- Track and validate remediation of identified issues within Compliance
- Provide independent challenge within the 2LoD function, ensuring high standards of oversight and accountability
- Partner with:
- 2LoD Financial Crimes leadership
- Model Risk Management (for CRR and TM models)
- Internal Audit (3LoD) for alignment on assurance coverage
- Support regulatory exams by demonstrating the effectiveness and rigor of 2LoD oversight and QA practices
- Identify opportunities to enhance 2LoD QA through:
- Standardization of oversight practices
- Enhanced documentation and governance protocols
- Use of data analytics to identify anomalies or inconsistencies in 2LoD outputs
- Monitor regulatory developments and industry expectations related to 2LoD responsibilities
- Support training and calibration efforts to improve consistency in 2LoD decision-making
- Lead and develop a team of QA analysts focused on 2LoD activities
- Ensure consistent application of QA methodology and standards
- Oversee QA planning, execution, and reporting timelines
- Promote a culture of rigor, independence, and continuous improvement within Compliance
Requirements
- Bachelor’s degree in Finance, Business, Risk Management, or related field
- 7–10+ years of experience in Financial Crimes (AML, Sanctions, Fraud), with direct experience in:
- 2LoD Compliance / Financial Crimes oversight, or
- Quality Assurance / Testing of Financial Crimes functions
- Strong knowledge of:
- BSA/AML and sanctions regulatory expectations
- 2LoD roles and responsibilities within a three lines of defense model
- Financial crime risk management frameworks and governance practices
- Experience reviewing complex financial crime cases and providing oversight or challenge
- Strong analytical and judgment skills
Nice to Have
- CAMS, CFE, CRCM, or similar certifications
- Experience with Customer Risk Rating (CRR) or Transaction Monitoring model governance
- Familiarity with regulatory exams and supervisory expectations for Compliance functions
- Experience leveraging data analytics or reporting tools in QA
Work Arrangement
Hybrid
Additional Information
- This role is also eligible for an annual performance-based incentive opportunity.
- Pathward offers a comprehensive benefits package for eligible employees, including health insurance, 401(k) retirement benefits, life insurance, disability benefits, paid time off, and more.
