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Job Summary

The Sponsor Bank EFCC Principal acts as the definitive authority and lead advisor on the enterprise-wide financial crime compliance (EFCC) governance framework. This role dictates the strategic vision and institution-wide control requirements for adherence to the Bank Secrecy Act (BSA), USA PATRIOT Act, and OFAC. Serving as the primary counsel to the BSA Officer and Executive Leadership, the Principal renders authoritative, risk-based decisions on complex compliance matters and new business initiatives, particularly those involving BaaS and Fintech partners. This leader directs the enterprise BSA/AML Risk Assessment, governs major regulatory programs, and provides credible challenge across business lines to ensure systemic risks are effectively mitigated. As the lead SME, the Principal represents and defends the Bank's compliance program in critical regulatory examinations and high-stakes audits, safeguarding the organization's license to operate.

Essential Job Functions

• Serve as the primary AML subject matter expert for the due diligence, risk assessment, and onboarding of all new Banking as a Service (BaaS) and Fintech partners, ensuring their control frameworks meet the bank's rigorous standards before integration. - (20%)
• Provide authoritative, risk-based counsel directly to the BSA Officer, executive management, and the Board of Directors on the specific, inherent, and evolving financial crime risks associated with the BaaS business model. - (15%)
• Author, maintain, and own the enterprise-wide BSA/AML/OFAC policies and standards, with a specific focus on developing and refining the governance framework for third-party BaaS relationships. - (10%)
• Direct the new product and initiative approval (NPIA) process for all BaaS-related offerings, ensuring AML risks are identified and requisite controls are embedded in the design prior to launch. - (10%)
• Lead the execution of the enterprise-wide BSA/AML Risk Assessment, paying special attention to the unique risk typology of the BaaS portfolio, and translate findings into actionable policy updates and control enhancements. - (10%)
• Act as the primary advisor and liaison to regulatory examiners (e.g., OCC, FDIC, Federal Reserve) and internal audit during examinations, managing all BaaS-related compliance inquiries, policy discussions, and formal responses. - (10%)
• Develop and present executive-level reporting and Key Risk Indicators (KRIs) for management and Board-level committees, clearly articulating the compliance health, risk profile, and control effectiveness of the BaaS partner ecosystem. - (10%)
• Provide strategic governance and credible challenge for the remediation of all BaaS-related regulatory findings (e.g., MRAs, Consent Orders) or internal audit issues, ensuring corrective actions address the root cause and are sustainably implemented - (5%)
• Benchmark all BaaS-related AML policies, procedures, and controls against regulatory guidance (e.g., FFIEC, FinCEN) and industry best practices to ensure the program remains current, effective, and defensible. - (5%)
• Establish and govern the three lines of defense model as it applies to BaaS partners, defining the clear roles, responsibilities, and oversight expectations for the business line, compliance, and audit functions. - (5%)

Minimum Qualifications

• High School Diploma or GED
• Certified Anti-Money Laundering Specialist (CAMS)
• 12+ years of experience in BSA, AML, Fraud, Compliance, Audit, Quality Assurance, or Quality Control operations

Preferred Qualifications

• Bachelor’s Degree in Business, Accounting, Criminal Justice, Analytics, Law, or Finance.
• Certified Regulatory Compliance Manager (CRCM)
• Certified Fraud Examiner (CFE)
• 15+ years of experience in BSA, AML, Fraud, Compliance, Audit, Quality Assurance, or Quality Control operations

Skills

• Structured Query Language (SQL)
• Microsoft Excel Data Analysis
• Microsoft Excel Macros
• Pivot Tables
• Customer Due Diligence (CDD)
• OFAC Compliance
• Bank Regulations
• Risk Training
• Financial Crimes Compliance
• Fraud Risk Management

Reports To: Director and above

Direct Reports: 0

Work Environment

• Normal office environment. (Remote or Hybrid), 3 to 4 days per month are required in office if within 60 miles of a posted Bread Financial location.

Travel

• Ability to travel up to 10% annually

Physical and Mental Requirements

To perform this job successfully, an individual must be able to perform each essential job function satisfactorily and meet the physical, mental and work environment requirements. Reasonable accommodations may be made to enable qualified individuals with disabilities to perform essential job functions, absent undue hardship.

• Communicate/Hearing
• Communicate/Talking
• Move/Traverse
• Reaching
• Standing
• Stationary Position/Seated
• Typing/Writing

Other Duties

This job description is illustrative of the types of duties typically performed by this job. It is not intended to be an exhaustive listing of each and every essential function of the job. Because job content may change from time to time, the Company reserves the right to add and/or delete essential functions from this job at any time.

Salary Range (unless otherwise noted below):

$133,500.00 - $241,900.00

Full Salary Range for position:

California: $153,500.00 - $302,400.00

Colorado: $133,500.00 - $254,000.00

New York: $146,800.00 - $302,400.00

Washington: $140,100.00 - $278,200.00

Maryland: $140,100.00 - $266,100.00

Washington DC: $153,500.00 - $278,200.00

Illinois: $133,500.00 - $266,100.00

New Jersey: $153,500.00 - $278,200.00

Vermont: $133,500.00 - $241,900.00

Ohio: $133,500.00 - $241,900.00

The actual base pay within this range may be dependent upon many factors, which may include, but are not limited to, work location, education, experience, and skills.

Bread Financial offers medical, prescription drug, dental, vision, and other voluntary benefits (including basic and optional life insurance, supplemental medical plans, and short and long-term disability) to eligible associates (regular full-time associates scheduled to work 30 hours per week or more) and their spouses/domestic partners, and child(ren) under the age of 26. New associate elected coverage begins on date of hire (with the exception of disability coverage which has a 6-month waiting period). Six weeks of 100% paid parental leave for eligible parents is available after a 180-day waiting period. Hired associates can immediately enroll in Bread Financial’s 401(k) plan.

All associates receive 11 paid holidays. Associates have discretion in managing their time away from work through the Flexible Time Off (FTO) program and may need to notify and receive approval from their manager prior to taking the time off. Associates (except those located in Illinois) receive 80 hours of Paid Sick and Safe Time (“PSST”) upon hire and at the beginning of each subsequent calendar year. Illinois associates receive 40 hours of Illinois PSST upon hire and at the beginning of each subsequent calendar year and 40 hours of Illinois Paid Leave upon hire and at the beginning of each subsequent calendar year. Illinois Paid Leave must be used before associates in Illinois will be approved to take FTO.

Hired associates will be able to elect the purchase company stock during offering periods in June and December. You will be eligible for an annual incentive bonus based on individual and company performance.

Click here for more Benefits information.

About Bread Financial

• Bread Financial offers competitive pay, a comprehensive selection of benefit options including 401(k).
• The Company is an Equal Opportunity Employer.
• Any applicant offered employment will be required to establish that they are legally authorized to work in the United States for the Company.
• The Company participates in E-Verify.
• The Company will consider for employment all qualified applicants, including those with a criminal history, in a manner consistent with the requirements of all applicable federal, state, and local laws, including the Los Angeles Fair Chance Initiative for Hiring Ordinance, the San Francisco Fair Chance Ordinance, and the New York City Fair Chance Act. Applicants with criminal histories are encouraged to apply.
• The Company complies with the Americans with Disabilities Act (ADA), as amended, and all applicable state/local laws. The Company will provide accommodations to applicants needing accommodations to complete the application process. Applicants with disabilities may contact the Company to request and arrange for accommodations. If you need assistance to accommodate a disability, you may request an accommodation at any time. Please contact the Recruiting Team at TaOps@breadfinancial.com.

Job Family:

Enterprise Risk

Job Type:

Regular