Director, Financial Crimes Compliance

About the role

As the Director, Financial Crimes Compliance you will play a key role in providing guidance in supporting Upstart Bank's FCC program. If you are excited by designing scalable compliance solutions, and building trusted relationships across a fast-moving fintech, this role is for you. How you'll make an impact Develop, implement, and maintain Upstart's Enterprise-Wide BSA/AML/OFAC Compliance Program, ensuring it remains aligned with regulatory requirements, evolving financial crime risks, and the company's risk appetite. Lead enterprise-wide BSA/AML and sanctions risk assessments, identify emerging risks, and establish risk-based controls, monitoring frameworks, and governance processes to mitigate financial crime exposure. Present regular reporting to the Board of Directors, executive leadership, and risk committees, including risk assessment results, program effectiveness metrics, key risk indicators (KRIs), regulatory developments, and remediation progress. Manage a comprehensive Customer Identification Program (CIP), Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) framework, including oversight of customer risk rating methodologies and ongoing monitoring activities. Oversee the review and management of high-risk customer relationships, including onboarding decisions, periodic reviews, escalation processes, and recommendations regarding customer exits or relationship terminations. Provide senior-level oversight and strategic guidance for complex investigations involving unusual activity, suspicious activity reporting (SAR), and regulatory reporting obligations. Serve as the primary point of contact for regulatory examinations, independent audits, and compliance reviews related to BSA/AML and sanctions compliance, ensuring timely and effective remediation of identified issues. Partner with Product, Engineering, Operations, Legal, and Risk teams to design scalable financial crime controls for new products, including consumer deposit and lending products. Monitor regulatory developments and provide guidance on BSA, AML, sanctions, fraud, and related financial crime compliance requirements impacting Upstart's business.

Requirements

• Bachelor's degree in Business, Finance, Accounting, Criminal Justice, Law, or a related field.
• 10+ years of experience leading BSA/AML compliance programs within a bank, credit union, fintech, or other regulated financial institution.
• Deep knowledge of the Bank Secrecy Act (BSA), USA PATRIOT Act, OFAC sanctions requirements, FinCEN guidance, Know Your Customer (KYC) ,Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Suspicious Activity Reporting (SAR) requirements.
• Experience completing BSA/AML/OFAC risk assessments and using the results to build, enhance, and manage BSA/AML compliance programs supporting consumer deposit products and lending products.
• Experience overseeing high-risk customer programs, customer risk rating methodologies, enhanced due diligence reviews, and customer relationship termination decisions.
• Demonstrated experience leading regulatory examinations, independent audits, and remediation efforts related to BSA/AML and sanctions compliance.
• Experience presenting financial crime compliance matters, risk assessments, and program metrics to senior executives, risk committees, and B

Additional Information

About Upstart At Upstart, we're united by a mission that matters: to radically reduce the cost and complexity of borrowing for all Americans. Every day, we bring creativity, experimentation, and advanced AI to reshape access to credit, helping millions move forward financially with clarity and confidence. As the leading AI lending marketplace, we partner with banks and credit unions to expand access to affordable credit through technology that's both radically intelligent and deeply human. Our platform runs over one million predictions per borrower using more than 1,800 signals, powering smarter, fairer decisions for millions of customers. But the numbers only hint at the impact. Every idea, every voice, and every contribution moves us closer to a world where credit never stands between people and their financial progress. We're proudly digital-first, giving most Upstarters the flexibility to do their best work from wherever they thrive, alongside teammates across 80+ cities in the US and Canada. Digital-first doesn't mean distant. We're intentional about in-person connection through team onsites, planning sessions, and moments that spark creativity and trust. And whether you choose to work primarily from home or collaborate in-person from one of our offices in Columbus, Austin, the Bay Area, or New York City (opening Summer 2026), you'll have the support to work in the way that works best for you. If you're energized by tackling meaningful problems, excited to innovate with purpose, and motivated by work that truly matters, we'd love to hear from you.

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