Financial Crimes Quality Assurance Manager

About the Role:

The Financial Crimes Quality Assurance (QA) Manager is responsible for overseeing and executing a quality assurance program focused on Second Line of Defense (2LoD) Financial Crimes activities, including oversight, review, challenge, and governance functions across BSA/AML, Sanctions, and Fraud.

This role ensures that 2LoD processes—such as alert oversight, customer risk rating governance, policy interpretation, and escalation decisions—are performed with consistency, accuracy, and in alignment with regulatory expectations and internal standards. The Manager will assess the effectiveness of 2LoD outputs, provide credible challenge within Compliance, and deliver insights to strengthen oversight and risk management practices.

What You Will Do:

Quality Assurance Oversight

• 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

QA Review Execution

• 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

Thematic & Horizontal Reviews

• 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

Framework & Methodology Development

• 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

Issue Management & Reporting

• 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

Stakeholder Engagement & Credible Challenge

• 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

Continuous Improvement

• 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

Team Leadership

• 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

What You Will Need:

Required

• 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

Preferred

• 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

Key Competencies

• Strong sense of independence and professional skepticism
• Ability to assess quality of judgment and oversight (not just execution)
• Excellent written and verbal communication skills
• Ability to influence and challenge peers within Compliance
• Attention to detail with a focus on consistency and governance
• Strong organizational and problem-solving skills

Success Metrics

• Quality and consistency of 2LoD QA reviews
• Identification of meaningful gaps in oversight and challenge
• Reduction in repeat QA findings within 2LoD
• Timeliness and effectiveness of issue remediation
• Positive feedback from regulators and Internal Audit on 2LoD QA program
• Demonstrated improvement in 2LoD governance and decision-making quality

The responsibilities listed above are not all inclusive and may be changed at any time.

Salary range:  $72,000 – $120,000

 
The salary range reflects the minimum and maximum target for a new hire in this role. Individual pay within the range will be determined by multiple factors which can include but are not limited to a candidate’s experience, qualifications, skills, and location. Your recruiter can share more about the specific salary for your location during the hiring process. Ranges may be modified in the future.
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.

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