Compliance Manager

Job Overview

The Compliance Manager supports the Chief Compliance Officer in the administration, enhancement, and oversight of the Company's BSA/AML and OFAC Programs applicable to its Private Placement Life Insurance (PPLI), Private Placement Variable Annuity (PPVA), and IFE operations in Puerto Rico.

As a key compliance leader, the Compliance Manager manages day-to-day compliance operations, supervises compliance personnel, and ensures the effective implementation of risk-based controls designed to detect and prevent money laundering, terrorist financing, sanctions violations, fraud, and other financial crimes. The role requires significant experience supporting high-net-worth (HNW) and ultra-high-net-worth (UHNW) clients, complex ownership structures, trusts, family offices, private investment companies, and international business relationships.

Job Responsibilities

Program Oversight and Governance

• Oversee day-to-day BSA/AML, OFAC, and financial crimes compliance activities.
• Develop, enhance, and maintain compliance policies, procedures, and controls.
• Lead periodic BSA/AML, OFAC, and country risk assessments.
• Prepare reports for executive management and compliance committees.
• Serve as Secretary of the local Compliance Committee.
  

Client Due Diligence and Risk Review

• Supervise customer due diligence (CDD), enhanced due diligence (EDD), source of wealth, source of funds, and beneficial ownership reviews.
• Review high-risk relationships involving trusts, foundations, family offices, offshore entities, private investment companies, and politically exposed persons (PEPs).

Monitoring, Investigations, and Reporting

• Supervise compliance monitoring, investigations, testing, requests for information (RFIs), and quality control activities.
• Review suspicious activity investigations and make recommendations regarding regulatory reporting and escalation.

Examinations, Audit, and Independent Testing

• Coordinate regulatory examinations, independent testing engagements, and audits.

Advisory and Business Support

• Provide compliance guidance to underwriting, operations, finance, distribution partners, and senior management.
• Participate in new product reviews, new business initiatives, and regulatory change management efforts.

Leadership and Team Development

• Directly supervise Senior Compliance Associates and Compliance Associates, including coaching, performance management, and professional development.
• Foster a culture of accountability, collaboration, and continuous improvement within the compliance function.

Skills and Qualifications

• Strong knowledge of the Bank Secrecy Act, USA PATRIOT Act, FinCEN requirements, OFAC regulations, and risk-based compliance principles.
• Strong working knowledge of compliance onboarding and monitoring systems (e.g., Enhanced Compliance System) and OFAC sanctions screening systems (e.g., World-Check, FedLink).
• Proficiency with Microsoft Office, including Word, Excel, and PowerPoint.
• Strong written and verbal communication skills in English and Spanish.
• Sound judgment, integrity, and an unwavering commitment to confidentiality, regulatory compliance, and ethical business practices.
• Strong analytical and problem-solving skills.
• Ability to collaborate effectively with cross-functional teams, including senior management.

Job Requirements

• Bachelor's degree required; majors in Accounting or Finance strongly preferred.

• Minimum of 10 years of AML/BSA, OFAC, compliance, legal, regulatory, or financial crimes experience.
• Demonstrated experience managing compliance programs.
• Demonstrated experience leading and developing compliance teams through effective coaching, performance management, and employee development.
• Experience supporting HNW and UHNW clients and complex ownership structures.
• Juris Doctor (J.D.) strongly preferred; attorney licensed in a U.S. jurisdiction preferred.
• Professional certification such as ACAMS, CPAML, or CRCM preferred.
• Experience with PPLI, PPVA, insurance carriers, private banks, trust companies, wealth management firms, family offices, or Puerto Rico IFEs.
• Experience interacting with regulators, auditors, and independent testing firms.