Manager, BSA/AML Operations
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About the role
The Manager, BSA/AML Operations is responsible for leading the alert review, case investigation, and regulatory reporting functions across Pathward's full BSA/AML risk footprint, including Issuing (prepaid, GPR, payroll, government benefit, and gift card programs), Lending (consumer and commercial), Tax/Refund products, Commercial DDA, Merchant Acquiring (sponsored merchants, payment facilitators, ISOs, and acquiring partners), Banking-as-a-Service (BaaS), and Partner-managed programs. This role manages a team of analysts who review alerts, investigate cases, and prepare SAR/CTR filings across these business lines. The Manager ensures that investigative workflows align with Pathward's BSA/AML policies, OCC supervisory expectations, FinCEN guidance, FFIEC BSA/AML Manual standards, and applicable card network compliance requirements, and that line-of-business-specific typologies including transaction laundering, structuring, layering, ERO fraud, refund fraud, merchant misclassification, prohibited merchant activity, chargeback fraud, and trafficking-related red flags are effectively detected, investigated, and reported. Scope of Responsibility: Provides direct oversight of analysts responsible for alert review, case investigations, SAR/CTR reporting, and partner referral dispositioning across all BSA/AML business lines, including a dedicated focus on Merchant Acquiring Manages operational performance across all assigned workstreams, ensuring adherence to SLAs, quality standards, and production targets Serves as a subject-matter expert on BSA/AML financial crime risks across Pathward's business lines, with deep expertise in Merchant Acquiring typologies and card network compliance considerations Does not own underwriting, partner onboarding, card network compliance, or first-line product risk management, but coordinates closely with those functions on risk signals and emerging trends Escalates high-risk or complex matters, including MATCH list entries, card network monitoring program flags, suspected terrorist financing, undisclosed sub-program activity, structuring, and other systemic concerns Maintains current knowledge of BSA/AML and OFAC regulations, FinCEN guidance, card network rules, and evolving fraud and money laundering typologies across all supported business lines Collaborates with BSA/AML peers, Sanctions Operations, Fraud Risk Management Operations, Program Risk Management, and FCC Program & Technology Assurance to ensure comprehensive risk coverage
Responsibilities
- Ensure alerts and cases across Issuing, Lending, Tax/Refund, Commercial DDA, Merchant Acquiring, BaaS, and Partner-managed programs are reviewed, investigated, documented, and dispositioned in accordance with Pathward procedures and regulatory requirements
- Maintain accountability for the alert-to-SAR lifecycle, including SAR identification, narrative quality review, timely filing, and CTR accuracy across all business lines
- Oversee investigation of business-line-specific typologies, including:
- Issuing: structuring, rapid cycling, dormant account misuse, prepaid layering, GPR/payroll velocity, trafficking-related red flags
- Lending: loan stacking, early payoff with third-party funds, payment activity inconsistent with borrower profile, ERO fraud
- Tax/Refund: refund fraud, ERO misuse, inflated withholdings, identity theft indicators
- Commercial DDA: flow-through of funds, shell company indicators, wire activity inconsistent with stated business purpose
- Merchant Acquiring: transaction laundering, factoring, MCC misclassification, prohibited merchant activity, chargeback misrepresentation, load balancing, BIN attacks, velocity attacks, and MID-cycling
- BaaS / Partner Programs: nested account abuse, undisclosed sub-program activity, partner-driven risk deterioration
- Review and disposition partner referrals and escalations across all business lines, including sponsored merchants, sub-merchants, payment facilitators, program
Benefits
Additional Information
We are a hybrid, remote-office company dedicated to growing our talent anywhere! We have onsite locations in: Sioux Falls, SD, Scottsdale, AZ, Louisville, KY, Troy, MI, Franklin, TN, Easton, PA. At Pathward, we take tremendous pride in our purpose to create financial inclusion for all™. We are a financial empowerment company that works with innovators to increase financial availability, choice, and opportunity for all. We strive to remove barriers that traditional institutions put in the way of financial access, and promote economic mobility by providing responsible, secure, high quality financial products. We are a team of problem solvers and innovators who celebrate our differences and know that our unique perspectives make us stronger and well-positioned for success. We celebrate, and embrace, our team members through our *HUMBLE*HUNGRY*SMART approach, and we believe that we are strongest when we embrace the voices of our employees, customers, partners, and the communities we serve.
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