CCO & BSA Officer

Chief Compliance Officer & BSA Officer We are seeking a Chief Compliance Officer & BSA Officer to serve as the cornerstone of our regulatory and compliance infrastructure. Reporting directly to the CEO and Board, you will be responsible for designing, implementing, and overseeing the full spectrum of compliance and financial crimes programs as we progress through OCC chartering and into full operations. This role is both strategic and hands‑on. In the near term, you will be the primary compliance voice in our charter application process and will build the foundational policies, procedures, and controls that will define how we operate as a regulated bank. As the company scales, you will build and lead a compliance team commensurate with our growth. What You’ll Do BSA/AML Program Leadership Design and own the enterprise‑wide BSA/AML/OFAC compliance program from inception, including policies, procedures, controls, and governance frameworks. Serve as the designated Bank Secrecy Act Officer of record. Oversee Customer Identification Program (CIP), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) policies. Establish and manage SAR and CTR filing processes, ensuring accuracy, timeliness, and defensibility. Build and oversee transaction monitoring systems, working closely with technology and data teams to define rules, thresholds, and alert logic. Lead OFAC screening and sanctions compliance, including list management and alert resolution frameworks. Regulatory & Charter Strategy Serve as a primary compliance liaison in the OCC national bank charter application process, including preparation of compliance program narratives, responses to regulatory inquiries, and pre‑examination readiness. Build relationships with OCC examiners, FinCEN, and other relevant regulators as the company progresses through licensing milestones. Ensure compliance with all applicable federal banking laws and regulations, including the Bank Secrecy Act, USA PATRIOT Act, Gramm‑Leach‑Bliley Act, Regulation E, Regulation Z, and applicable UDAAP standards. Monitor evolving regulatory guidance and assess impact on business operations and product roadmap. Program Development & Infrastructure Develop and maintain a comprehensive compliance management system, including risk assessments, policy libraries, training programs, and audit‑ready documentation. Partner with product, engineering, legal, and operations teams to embed compliance requirements into product design and operational workflows. Establish internal audit and testing protocols, including independent testing of the BSA/AML program. Oversee vendor due diligence and third‑party risk management as it relates to compliance obligations. Leadership & Board Engagement Report directly to the CEO and Board of Directors on compliance risk, program status, and material regulatory developments. Serve as a member of the senior leadership team, contributing to strategic planning and company‑wide risk management. Build, mentor, and lead a compliance team as headcount scales with business growth. Drive a culture of compliance across the organization through communication, training, and consistent accountability. What We’re Looking For The ideal candidate blends experience across three distinct environments: traditional banking, fintech, and the OCC charter process. We are not looking for a specialist in only one of these areas—this role requires someone who can translate the rigor of a regulated depository institution into the speed and scale of a technology‑driven product company, while simultaneously guiding us through one of the most demanding regulatory processes in financial services. Required Experience & Qualifications 10+ years of progressive compliance experience spanning traditional banking, fintech, and/or the intersection of both—candidates with a background in only one of these environments are unlikely to be the right fit. Prior experience as a designated BSA Officer or in a senior BSA compliance leadership role. Deep expertise in BSA/AML regulations, FinCEN guidance, OFAC requirements, and the USA PATRIOT Act. Hands‑on experience building or significantly rebuilding BSA/AML programs, including transaction monitoring, CIP/CDD/EDD, and SAR/CTR filing frameworks. Direct involvement in an OCC national bank charter or de novo charter process—familiarity with OCC licensing expectations, examination readiness, and the compliance program narratives required during the application process is essential. Background at or with a traditionally chartered bank (OCC or state‑chartered), providing grounding in how a regulated depository institution operates under full federal oversight. Experience in fintech or digital banking, with an understanding of high‑volume digital onboarding, API‑driven product delivery, and the compliance challenges unique to technology‑forward financial services. Demonstrated ability to work directly with federal bank examiners and regulatory agencies. Experience in consumer‑facing financial products including deposit accounts, payments, and/or lending. Preferred Background Experience at a fintech company operating under or alongside a chartered bank model (sponsor bank relationships, BaaS platforms, or direct charter). Familiarity with real‑time payments, cross‑border transactions, or global money movement compliance. CAMS certification strongly preferred; CRCM or other relevant certifications a plus. JD or advanced degree in a related field a plus, but not required. #J-18808-Ljbffr