Partner Banking Monitoring & Testing Lead

KEY RESPONSIBILITIES: Monitoring & Testing Program • Build and maintain a comprehensive monitoring and testing framework for partner banking activities, including methodology, testing procedures, workpaper requirements, evidence standards, quality assurance, and reporting. • Establish and maintain the testing universe, control inventory, and annual risk-based testing plan. • Determine testing frequency and scope based on partner risk, product exposure, regulatory requirements, and broader enterprise and financial crime risk assessments. • Perform testing directly while developing the function and expand the team as coverage requirements grow. Partner & Third-Party Control Testing • Evaluate controls across different partner banking and account structures, including managed accounts, FBO accounts, omnibus arrangements, and similar models. • Test the effectiveness of controls performed by third parties where the institution relies on fintech partners for KYC/KYB, transaction monitoring, escalation, or other compliance activities. • Conduct partner oversight reviews and assessments covering BSA/AML, sanctions, fraud, consumer compliance, and operational controls. • Evaluate whether partner activities remain consistent with approved structures, risk parameters, licensing requirements, and compliance obligations. BSA/AML & Sanctions Testing • Test CIP/KYC/KYB, beneficial ownership, customer risk rating, transaction monitoring, alert and case management, SAR processes, and sanctions screening controls. • Assess transaction monitoring coverage, scenario effectiveness, tuning practices, investigation quality, and escalation processes. • Evaluate screening and controls involving higher-risk customers, industries, jurisdictions, counterparties, and transactions. • Partner with financial crimes and compliance leadership to identify control weaknesses and validate remediation. Operational, Recordkeeping & Reconciliation Testing • Test reconciliation and recordkeeping controls associated with partner banking and sub-account structures. • Assess whether account records and supporting processes meet applicable requirements for deposit account structures and pass-through deposit insurance treatment. • Review partner licensing and registration requirements relevant to payment and money transmission activities. • Trace data and transaction flows across partner integrations to identify gaps between documented processes and actual control execution. Digital Asset & Stablecoin Testing • Evaluate controls associated with stablecoin and blockchain-based payment activity, including conversion activity, issuance and redemption processes, wallet and counterparty screening, and blockchain analytics. • Assess controls related to Travel Rule requirements, unidentified or unattributed transactions, and digital asset activity occurring outside traditional banking hours. • Evaluate whether transaction monitoring and sanctions controls appropriately address digital asset and blockchain-related risks. Consumer Compliance Testing • Test partner compliance with applicable consumer protection requirements, including UDAAP/UDAP, Regulation E, Regulation P, and deposit insurance advertising and disclosure requirements. • Evaluate partner marketing materials, disclosures, complaints, disputes, and other customer-facing processes. • Expand testing coverage to applicable lending and credit requirements, including TILA, ECOA, and FCRA, as relevant products are introduced. Issues, Remediation & Validation • Document testing findings with clear supporting evidence, risk severity, ownership, and root-cause analysis. • Track corrective actions and remediation commitments through completion. • Independently validate that remediation is effective and supported by sufficient evidence before issues are closed. • Monitor completion of required partner reviews, conditional approvals, and other risk or compliance commitments. Technology & Data-Driven Testing • Use data analytics, automation, and AI-enabled tools to improve testing efficiency and expand coverage beyond traditional sampling where appropriate. • Apply data mapping and full-population analysis to identify control weaknesses, anomalies, and potential compliance issues. • Evaluate technology-supported compliance and due diligence processes to determine whether outputs are accurate, complete, and appropriately controlled. Leadership & Regulatory Support • Recruit, develop, and manage monitoring and testing professionals as the function grows. • Establish consistent testing and documentation standards and provide quality oversight across the team. • Present testing results, significant control deficiencies, trends, and remediation status to senior management and governance committees. • Support regulatory examinations and internal audits by preparing testing documentation, evidence, responses, and remediation updates. • Monitor supervisory guidance and enforcement developments affecting fintech partnerships, third-party banking, and digital assets and incorporate relevant changes into testing coverage.

QUALIFICATIONS: • 8+ years of experience in compliance monitoring and testing, internal audit, risk management, or compliance within banking or financial services. • Direct experience testing fintech partner, sponsor bank, BaaS, or comparable third-party banking programs. • Demonstrated experience building or leading a risk-based monitoring and testing program, including ownership of the testing universe, annual plan, methodology, issue management, and senior-level reporting. • Experience testing or auditing partner banking structures such as managed accounts, FBO accounts, omnibus arrangements, or similar models. • Experience evaluating reliance on third-party KYC/AML controls as well as related recordkeeping and reconciliation processes. • Experience conducting fintech partner oversight reviews covering BSA/AML, sanctions, fraud, consumer compliance, and related controls. • People management experience, including developing and overseeing testing, audit, compliance, or risk professionals. • Working knowledge of consumer protection requirements applicable to fintech partnerships, including UDAAP/UDAP, Regulation E, Regulation P, and applicable deposit insurance advertising and disclosure requirements. • Familiarity with regulatory expectations governing third-party relationships, sponsor banking, and fintech partnerships. • Experience presenting significant findings to senior management or governance committees and supporting federal banking examinations. • Experience managing findings, overseeing remediation, and independently validating corrective actions through closure.

PREFERRED QUALIFICATIONS: • Experience testing digital asset or stablecoin controls, including blockchain analytics, wallet screening, counterparty screening, or Travel Rule requirements. • Familiarity with money transmission, MSB, digital asset, or similar licensing and registration requirements. • Experience addressing significant regulatory findings, supervisory matters, or formal remediation programs through closure. • Experience within a federally regulated bank or active sponsor banking environment. • Familiarity with GRC, audit management, data analytics, AI-enabled compliance, or similar technology platforms. • CAMS, CRCM, CIA, CPA, or another relevant professional certification.