Manager, BSA/AML Operations, Merchant Acquiring

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

What You Will Do:

• 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 managers, and corporate funders
• Ensure timely response to 314(a) requests, 314(b) inquiries, law enforcement inquiries, subpoenas, and grand jury process across all business lines

Risk Intelligence & Coverage Support

• Provide investigative insights and trend data across all business lines to inform AML Transaction Monitoring Coverage Assessments, rule-tuning, scenario optimization, and AML Risk Assessment refreshes
• Identify emerging fraud and AML risks based on alert trends, SAR filings, no-file decisions, partner behavior, and external threat intelligence
• Coordinate with the Director, Financial Crime Risk Intelligence on cross-business-line risk narratives and escalation of novel or systemic issues
• Support red flag inventory updates with business-line-specific indicators across Issuing, Lending, Tax/Refund, Commercial DDA, Merchant Acquiring, and BaaS

Team Leadership & Quality

• Manage, mentor, and develop a team of BSA/AML analysts with coverage across multiple business lines, including onboarding, training, and performance management
• Establish and monitor QC standards across all assigned workstreams; identify themes and implement remediation
• Ensure training materials reflect current typologies, regulatory expectations, card network rules, and Pathward product specifications across all supported business lines
• Support analyst development and specialty queue assignment to build SME depth and operational resilience

Governance & Reporting

• Develop and maintain KPIs/KRIs across all supported workstreams (alert volumes, aging, SAR counts, false-positive rates, chargeback-driven referrals, partner referral throughput)
• Contribute to Board reporting, exam responses, validation submissions, and management action plans
• Partner with Program Risk Management, FCC Program & Technology Assurance, and Compliance on partner oversight, deterioration signals, and regulatory commitments

What You Will Need:

• Bachelor’s degree required (Finance, Criminal Justice, Accounting, Business, or related field)
• CAMS or equivalent AML certification strongly preferred
• Advanced certifications (e.g., CFE) a plus
• 5–7 years of experience in BSA/AML investigations, financial crimes compliance, or fraud operations, with at least 2 years focused on merchant acquiring, payment facilitation, or card network compliance
• Demonstrated experience managing alert/case production teams and SAR filing processes
• Strong knowledge of merchant acquiring risks: transaction laundering, MCC misclassification, chargeback fraud, prohibited merchant categories, and card network monitoring programs (Visa VFMP, Mastercard BRAM)
• Familiarity with Actimize, FCRM, or similar transaction monitoring and case management platforms
• Working knowledge of BSA/AML regulations, FinCEN guidance, OCC supervisory expectations, and FFIEC BSA/AML Manual

The responsibilities listed above are not all inclusive and may be changed at any time.

Salary range: $72,000 – $120,000

The salary range reflects the minimum and maximum target for a new hire in this role. Individual pay within the range will be determined by multiple factors which can include but are not limited to a candidate’s experience, qualifications, skills, and location. Your recruiter can share more about the specific salary for your location during the hiring process. Ranges may be modified in the future.
This role is also eligible for an annual performance-based incentive opportunity. Pathward offers a comprehensive benefits package for eligible employees, including health insurance, 401(k) retirement benefits, life insurance, disability benefits, paid time off, and more.

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