Director, Financial Crimes Compliance

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.

Minimum Qualifications

• 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 Boards of Directors.
• Knowledge of consumer banking regulations applicable to deposit and lending products.

Preferred Qualifications

• CAMS (Certified Anti-Money Laundering Specialist), CAFP (Certified AML and Fraud Professional), CRCM, or comparable compliance certification.
• Experience serving as a BSA Officer, Deputy BSA Officer, or senior financial crimes compliance leader within a highly regulated financial institution.
• Experience building and scaling AML transaction monitoring, sanctions screening, customer risk scoring, and implementing case management programs.
• Experience using AI powered solutions to scale and automate BSA program work.
• Knowledge of digital banking, fintech, embedded finance, or marketplace lending business models.
• Experience implementing technology-enabled compliance solutions, automated controls, and risk monitoring frameworks.
• Experience working directly with federal and state banking regulators, including OCC, FDIC, Federal Reserve, CFPB, FinCEN, or state banking agencies.
• Familiarity with fraud risk management frameworks and the intersection of fraud and AML compliance programs.