Summit National Bank Hiring for Head of Customer Due Diligence Job at Remote Full Time

Head of Customer Due Diligence (“CDD”)

Remote position

Mode Eleven (the future name of Hulett Bancorp) is seeking an experienced Customer Due Diligence person to serve as Head of CDD for Hulett Bancorp and its subsidiaries, including Summit National Bank, as it launches a national FinTech Division. Mode Eleven have developed a technology stack and a

Banking-as-a-Service platform to offer a full-range of banking products and services to FinTechs and companies looking to offer embedded finance solutions.

Summit National Bank currently operates as a small community bank serving rural communities in

Wyoming, Montana and Idaho.

Overview

The CDD team is responsible for the onboarding of new customers for the Banking as a Service (“BaaS”) business, ongoing monitoring of customers, and maintaining the customer risk rating methodology.

Reporting to the Bank Secrecy Act/Anti-Money Laundering and Sanctions Officer, the Head of CDD is responsible for the day-to-day compliance efforts related to Bank Secrecy Act (“BSA”)/Anti Money

Laundering (“AML”), Office of Foreign Assets Control (“OFAC”) and Sanctions in accordance with Summit

National Bank (“SNB”) policies and procedures.

The Head of CDD assists the BSA/AML and Sanctions Officer with the day-to-day execution of the department and its activities. The Head of CDD will lead the development, implementation, and maintenance of an enterprise-wide system for obtaining information required by the company’s Know

Your Customer (“KYC”) and Customer Information Program (“CIP”) standards. The Head of CDD will oversee a team of resources provided by SNB’s managed services consulting company.

Responsibilities

Develops and updates appropriate processes and procedures for ongoing KYC, CDD and Enhanced Due

Diligence (“EDD”), periodic reviews and customer risk rating.

Supervises and oversees SNB’s managed services consulting company, ensuring the managed services provider complies with all regulatory requirements and SNB policies and procedures relating to KYC, CDD and EDD.

Ensures the performance, development and ongoing training of all assigned teams and the teams’ understanding of compliance with all policies and procedures.

Assists with workforce planning to ensure appropriate staffing.

Assists in evaluating improvements to the processes and systems that are used for KYC.

Lead, perform and coordinate CDD and/or EDD reviews of all customers and platforms, including adverse news research, investigation or analysis for special reviews.

Coordinate and communicate the enhanced due diligence review implications from customer screening for politically exposed persons, OFAC, FinCEN 314(a) and adverse news.

Lead and assist in managing implementation of the KYC system, or other enhancements necessary for due diligence processes.

Assist and coordinate in the UAT testing of the AML and KYC system implementation as necessary.

Identify and propose enhancements to customer risk rating models and ensure they are properly tuned to identify customers posing an increased money laundering risk to the institution.

Update and maintain consolidated lists of high-risk customers, account closures, rating changes, etc.

Assist in the development and delivery of BSA/AML training specifically focused on addressing customer identification and monitoring to all business lines.

Prepare and distribute monthly management reports detailing the composition of the customer due diligence, customer base, significant changes, risk ratings, and other relevant information on customer trends and patterns.

Develop close working partnerships with others across different internal departments and liaise regularly with clients, internal business development staff and other support functions.

Keep abreast of BSA/AML and Sanctions compliance and regulatory updates by attending continuing professional education and webinars, reading professional journals and articles, and networking with others in the profession.

Perform other related duties as assigned.

Qualifications

Expert-level understanding of legal aspects and recordkeeping requirements of banking regulations specifically AML, BSA, OFAC and the USA PATRIOT Act.

Expert-level knowledge of banking policies and applicable laws and regulations.

Strong understanding of customer due diligence related to financial institutions, correspondent banking and/or FinTechs.

Expert knowledge of systems and implementation related to KYC and CDD.

Knowledge of digital assets and blockchain technology and associated red flags, or the desire to gain knowledge.

Strong leadership skills and the ability to direct staff and workflows in accordance with bank standards.

Strong sense of accountability and ability to execute in a high-pressure and time-sensitive environment.

Strong presentation and communication skills.

Strong interpersonal skills.

7 to 10 years of specialized experience in Financial Services, FinTechs, Payments and/or Money Transfer preferred, with 5 years management experience.

Preferred: BA/BS (or equivalent experience)

Job Type: Full-time

Pay: $150,000.00 – $170,000.00 per year

Benefits:

• 401(k)
• 401(k) matching
• Dental insurance
• Flexible schedule
• Health insurance
• Health savings account
• Life insurance
• Paid time off
• Vision insurance

Schedule:

• Day shift
• Monday to Friday

Experience:

• Lexis-Nexis: 1 year (Preferred)

Work Location: Remote