A marijuana related business (MRB) Analyst is responsible for assisting with the coordination of WPCU’s MRB program functions enterprise wide and ensuring that WPCU MRB activities comply at all times with applicable laws and regulations. The MRB Analyst also ensures effective transaction monitoring, and MRB member account oversight occurs to identify risk and suspicious activity, including extensive due diligence. Upon identification of unusual activity, regulatory risk, or program deficiencies, takes appropriate actions to protect the credit union and ensure compliance with federal and state laws and regulations.
- Supports WPCU’s overall Bank Secrecy Act (BSA)/Anti-Money Laundering (AML)/Office of Foreign Assets Control (OFAC) program, specifically the MRB program, including assisting in day-to-day BSA/AML monitoring and reporting of MRB members. Utilizes expert knowledge of applicable guidance and regulations, such as the Cole Memo, to ensure compliance by WPCU and its members, at all times. This includes conducting in-depth investigations and accurately identifying and reporting of MRB Limited, MRB Priority, and MRB Termination Suspicious Activity Reports (SARs) and ongoing continuous 90-day SAR reviews, identification and drafting of Currency Transaction Reports (CTRs), high risk due diligence reviews, review of system triggered monitoring alerts, and completion of various data trending processes to identify spikes in activity that may be suspicious. Ensures all activities are properly documented for record retention purposes. (45%)
- Assists management with risk mitigation efforts pertaining to MRB members. This includes conducting quarterly on-site due diligence visits, completing monthly in-depth reviews of financial statements, and conducting on-going in-depth know your member processes to fully understand MRB account relationships, MRB vendor relationships, MRB member products and average sales, and day-to-day MRB operations. This includes conducting due diligence reviews to understand and document beneficial ownership of MRB relationships to 10%, understanding source of funds and presence of legacy funds during account opening, conducting negative news and OFAC searches, and review of Customer Identification Program (CIP) and Customer Due Diligence (CDD) collected information. Partners with Member Business Services (MBS) to engage with MRB account applicants to facilitate the collection, review, and analysis of due diligence information and to provide approval recommendations for MRB accounts to management. (30%)
- Assists with developing and revising practices and procedures, including procedures of applicable business units, as they relate to the MRB program; reports gaps in policies, procedures, and operating controls to management to ensure risk mitigation; (10%)
- Research compliance inquiries related to BSA and provide guidance to the business; (5%)
- Supports the oversight of regulatory compliance audits and/or examinations; (5%)
- Other duties as assigned. (5%)
Required Skills
The MRB Analyst has expert knowledge of BSA/AML laws and regulations, federal and state credit union regulations, as well as operating areas, functions, and products and of WPCU. The following are also preferred:
- A Bachelor’s degree in a business discipline.
- Applicable certification such as Certified Anti-Money Laundering Specialist (CAMS), Certified Anti-Money Laundering Fraud Professional (CAFP), or Bank Secrecy Act Compliance Specialist (BSACS) is required, or willingness to seek applicable certifications. At least 6 years’ experience in a depository financial institution with at least 5 years’ experience in a BSA/AML compliance role or comparable experience is required.
- Previous experience/knowledge of MRBs is preferred.
- Extraordinary attention to detail and problem-solving abilities.
- Strong customer relations and interpersonal skills.
- Ability to work under pressure and adaptable to changing conductions, including adjusting priorities on the fly.
- Ability to work independently in a fast-paced environment with tight deadlines.
- Takes initiative to learn, develop oneself and see tasks through from start to finish.
- Completion of annual education/training in BSA compliance.
- Excellent written and verbal communication skills.
Required Experience