Aml Compliance Officer

How Will This Role Impact First Command?

The Anti-Money Laundering Compliance Officer (AMLCO) administers First Command Brokerage Services (FCBS) and First Command Advisory Services, Inc.'s (FCAS) AML program and Fraud Prevention efforts.  The AMLCO develops, implements, and maintains policies and procedures that are reasonably designed to comply with legislation and regulatory rules set forth by The Department of the Treasury, Federal Trade Commission, SEC, and FINRA. The AMLCO will use automated trade review systems, develops trade review rules, and is responsible for reporting money laundering, fraud, identity theft or other such type of activity to the appropriate supervisory authority. 

What Will You Be Doing?

       Review and report out changes in AML regulation;

       Conduct an annual AML risk assessment and determine appropriate internal controls;

       Implement key changes identified in AML risk assessment;

       Develop, publish, and implement AML policies and procedures and determine appropriate tools to use for AML surveillance;

       Draft and submit Suspicious Activity Reports (SARs) as required under the Bank Secrecy Act and FINRA/SEC rules and regulations;

       Create and deliver annual AML training for First Command Home Office personnel and its field advisors;

       Coordinate and respond to Financial Crimes Enforcement Network (FinCEN) 314(a) requests;

       Coordinate with outside financial institutions via 314(b) information sharing requests;

       Ensure that an independent annual audit of the AML Compliance Program is conducted in accordance with FINRA rules and regulations;

       Identified and listed on FINRA Contact Forms as the Anti-Money Laundering contact for First Command Brokerage Services;

       Conduct AML surveillance using various software programs to detect suspicious activity and report this activity to the appropriate authorities;

       Act as the AML point of contact for the Regulatory Authorities and Law Enforcement Agencies and respond to inquiries from these agencies;

       Develop and update the surveillance rules for Pershing (Actimize), Protegent, and CIP tools;

       Create and review internal control reports including trade exception reports to minimize corporate risk from unsuitable trades, identity theft, fraud, or AML violations;

       Collaborate with First Command Team members as necessary to optimize and implement any changes to the identified controls;

       Briefs the Compliance Leadership team as appropriate with AML or Fraud Controls Exceptions and develop and implement those key controls to be put in place;

       Develop and support First Command's Vulnerable Clients policies and procedures, to include ensuring trusted contact information reported;

       Contact proper state agencies / authorities when abuse of vulnerable persons has been detected;

       Collaborate and support Internal Audit and Regulatory Examination teams with respect to information requests related to the AML Compliance Program;

       Collaborate with FCB BSA Compliance officer to ensure an enterprise-AML approach to the overall compliance program;

       Collaborate with the FCB Fraud Prevention Team to ensure an enterprise-AML approach to the overall compliance program.

Supervisory Responsibility

       The AMLCO reviews the activities of the Field and Home Office associated persons reporting any issues to the appropriate supervisory authority. In addition, he/she must oversee the Company's AML Program;

       These items will be reported on not less than a monthly basis on the department's metrics reports; and

       The AMLCO will be responsible for supervising any compliance staff with AML responsibilities.

What Skills/Qualifications Do You Need?

Education

        Bachelor's degree required; Equivalent experience may be considered.

Work Experience

        At least five (5) years AML compliance experience

        At least three (3) year experience in a broker-dealer environment

Certifications

        Certified Anti-Money Laundering Specialist (CAMS) designation required (may obtain the designation within 6 months of accepting the position.)

        Certified Fraud Examiner Designation required (may obtain the designation within 6 months of accepting the position.)

        General Securities License and Principal License (Series 24) preferred.

Required Knowledge, Skills and Abilities

• Must be familiar with Title III of the U.S. Patriot Act of 2001
• Must be familiar with FATF 40 and 7 Special Recommendations for Dismantling Terrorist Financing
• FTC Red Flag Rules
• Must be knowledgeable with FCFP's WSP and CM
• Must possess strong research and analytical skills
• Must possess effective communication skills
• Must be competent in using the following software:

o   Pershing NetX360

o   Actimize

o   Lexis Nexus

o   AS400 Phoenix Database

o   Visual Imaging

o   Protegent

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