Director - Compliance Officer (DFS 504)

Risk | Financial Crime Prevention Americas | Director - Compliance Officer (DFS 504) | New York

About ING: 

In Americas, ING’s Wholesale Banking division offers a broad range of innovative financial products and services to domestic and international corporate and institutional clients. 

When you come to work at ING, you’re joining a team where individuality isn’t just accepted, it’s encouraged. We’ve built a culture that’s fun, friendly and supportive – it’s the kind of place where you can be yourself and make the most of whatever you have to offer.

We give people the freedom to take risks, think differently, take ownership of their work, and make great things happen. We’re here to help you get ahead. And with our global network, there’s plenty of scope to take your career in new directions, perhaps even ones you’ve never considered. ING Americas follows a hybrid work model, allowing for in-office / work from home flexibility. Hybrid work arrangements vary based on business area.

Sound like the kind of place you’d feel at home? We’d love to hear from you.

About the position:

Candidates should be experienced in dealing with the specific requirements of DFS Part 504, including transaction monitoring, filtering (watchlist screening), model validation, and data governance.  Duties include designing, implementing, and maintaining robust transaction monitoring and filtering programs, and facilitating the annual certification requirement. 

About the department:

ING is seeking a highly experienced and motivated Compliance Officer  to lead the Firm’s efforts in implementing and managing a NYDFS 504 compliant transaction monitoring and sanctions screening program. The ideal candidate will have a strong background in DFS 504 compliance, and experience in overseeing transaction monitoring & sanctions screening programs.  This individual will be responsible for ensuring that ING’s programs meet all regulatory requirements and industry best practices.

Responsibilities :

Program Design and Implementation:

• Work with 1st Line and consultants on the development and implementation of 504 compliant programs for transaction monitoring and filtering, including build-out of automated systems, creation of risk views/alert definitions, system tuning, etc. 
• Ensure policies and procedures are in place to prevent transactions with sanctioned entities and identify potential BSA/AML violations. 
• Document all policies and procedures related to transaction monitoring and filtering. 

Compliance & Oversight:

• Manage and update procedures for transaction monitoring and filtering programs including alert handling, threshold tuning, and periodic assessments.
• Participate in annual risk assessments and mapping of risks to transaction monitoring program elements.  This includes identifying applicable money laundering typologies (i.e., red flags) related to products and services, as well as controls that mitigate risks (e.g., automated detection scenario, manual monitoring, KYC).
• Evaluate the adequacy of board and management oversight of transaction monitoring and filtering programs programs. 

Testing and Validation:

• Work with 1st line and consultants to conduct and document end-to-end and pre- and post-implementation testing of transaction monitoring and filtering programs. 
• Review governance, data mapping, transaction coding, detection scenario logic, model validation, data input, and program output. 

Certification & Reporting:

• Facilitate the preparation and submission of the required annual certification to DFS and ensure compliance with the 3 NYCRR 504 regulations. 
• Maintain records demonstrating compliance with Part 504 requirements. 
• Participate in SAR drafting and internal reporting process.

Other Responsibilities:

• Assist in identifying and addressing compliance issues and irregularities. 
• Answer employee and company leader questions about compliance issues. 
• Update company records for compliance-related data. 
• Liaise with regulators and central teams/service providers for matters related to transaction monitoring and filtering programs.

Specific DFS Part 504 Focus:

• Familiarity with the specific requirements of DFS Part 504, including transaction monitoring, filtering (watchlist screening), model validation, and data governance. 
• Understanding of the annual resolution by the board of directors or compliance findings by the Chief Compliance Officer. 
• Experience with Bank Secrecy Act (BSA)/Anti-money Laundering (AML) and Office of Foreign Assets Control (OFAC) regulations. 

Qualifications and Competencies

• Bachelor’s degree preferred.
• Professional certification such as Certified Anti-Money Laundering Specialist (CAMS), Certified Global Sanctions Specialist (CGSS) preferred.  These certifications must be obtained as part of the job if not already qualified.
• Prior experience in working with bank payment systems.
• Minimum of 10 years of experience in compliance, with a focus on AML and sanctions screening.
• In-depth knowledge of DFS504 regulations and other relevant compliance requirements
• Strong analytical, problem-solving, and decision-making skills.
• Excellent communication and interpersonal skills.
• Ability to work independently and as part of a team

Salary Range $216,000-273,000

In addition to comprehensive health benefits, a generous 401k savings plan, and competitive PTO, ING provides a broad array of benefits including adoption, surrogacy, and fertility services; student debt assistance; and subsidies for expenses associated with commuting and fitness.

ING is a committed equal opportunity employer. We welcome applicants of diverse backgrounds and hire without regard to race, gender, religion, national origin, citizenship, disability, age, sexual orientation, or any other characteristic protected by law. We celebrate these differences and rely upon your unique perspective to innovate and seize new opportunities. Come as you are.

ING Bank does not have a commercial banking license in the U.S. and therefore not permitted to conduct a commercial banking business in the U.S. Through its wholly owned subsidiary ING Financial Services LLC, and its affiliates, it offers a full array of wholesale products such as commercial lending and a full range of FM products and services.