Senior Manager: AML Broker Dealer Advisory

8th June 2017
Job Type


BSM Group are representing a client seeking a Senior Manager: AML Broker Dealer Advisory.

Key Responsibilities:

  • Serve as the dedicated advisory specialist in support of the Bank (“Firm”), a registered broker-dealer and future commission merchant (“FCM”), which is supervised, among others, by the Self-Regulatory Organizations (SROs), including the Financial Industry Regulatory Authority (“FINRA”) and the National Futures Association (“NFA”).
  • Provide appropriate support, as needed, for any AML/OFAC regulatory matters related to the Firm activities across all products and lines of business, including Prime Brokerage Services, Debit Capital Markets, Equity Capital Markets, Credit Sales & Trading, Institutional Equity Sales & Trading, and Emerging Markets.
  • In conjunction with Management, and in support of AML and OFAC broker-dealer compliance, draft and maintain the Firm’s written supervisory procedures (“WSPs”), including relevant supporting policies and procedures.
  • Stay current on critical and emerging regulatory topics and AML sweep exam topics, and their potential impact on the Firm’s business and sales activities.
  • Review, interpret and assess regulatory impact related to proposed or new AML rules, regulatory AML advisories as well as those mandated by the SROs, including FINRA Notices to Members.
  • Coordinate with the Firm’s Chief Compliance Officer to keep abreast of any new or emerging issues in order to align appropriate support for AML/OFAC regulatory matters revolving around any of the new Firm's activities.
  • Provide appropriate real-time AML/OFAC compliance advice to the relevant Firm front office, operations and trading floor personnel.
  • Conduct targeted and/or customized AML/OFAC training, including as part of the Firm Element training program, offered to the relevant front office, operations and trading floor personnel.
  • Assist with internal and external examinations, including FINRA exams, audits, inquiries, annual BSA/AML and OFAC Risk Assessments, and any similar reviews to ensure appropriate Firm coverage, including compiling of requested data and/or drafting responses as needed.
  • Lead regulatory, surveillance enhancements and other compliance projects, including remediation efforts, for projects driven by the Firm related to AML/OFAC deliverables.
  • Provide guidance and instructions to the Firm’s personnel in relation to their obligation to file an Unusual Transaction Report (“UTR”) with the U.S. Financial Intelligence Unit (“FIU”), should there be a reason to believe that a transaction or customer behaviour represents unusual or potentially suspicious activity.
  • Provide guidance to the Firm’s front office and operations teams regarding KYC information required for new customers during onboarding, or as needed during any related surveillance inquiries or investigation, to ensure that the Firm’s customers account activity is consistent with their KYC profiles.
  • Provide guidance and instructions to the U.S. FIU to assist in alert or case investigations involving the Firm or the Firm’s customers’ transactional activities, as appropriate.
  • Assist the Firm’s personnel with responding to a Request for Information (“RFI”), as submitted by the U.S. FIU, in order to obtain additional information to gain a better understanding of the Firm’s customers or their transactional activity.
  • Analyze the Firm’s trade surveillance activities, email surveillance or any related sales practice activities, including any relevant exception reports or related MIS reporting, in order to identify necessary enhancements to AML transaction monitoring rules and investigative processes, with a focus on the Firm’s customers and their activities.
  • Assist the U.S. Suspicious Activity Reporting (“SAR”) Committee, as needed, in assessing the appropriateness of the Firms customers’ unusual activity investigation cases that may potentially warrant a SAR, and assist in drafting of related SARs for subsequent filing with FinCEN.
  • Assist in preparing the Firm related MIS AML Monitoring Reports, as appropriate.


  • Strong understanding of the U.S. regulatory landscape.
  • Knowledge of broker-dealer and FCM regulatory requirements, including SROs guidance and industry best practices.
  • Keep up-to-date and abreast of evolving regulatory standards and/or industry trends in order to recommend potential enhancements to the Firm related processes, policies and procedures to ensure their continued effectiveness in support of the Bank’s BSA/AML and OFAC Compliance Programs.
  • A forward, innovative thinker and change leader who can identify and implement new trends.
  • Highly motivated, energetic, personable and comfortable working closely with and interacting with all levels of management.
  • Strong analytical, critical thinking, writing, communication and interpersonal skills, thorough and able to handle a wide range of issues varying in complexity.
  • Strong work ethic, team player, ability to make decisions and work under tight deadlines.
  • Experience in working on dynamic and multifaceted projects.
  • Ability to liaise with regulatory authorities as appropriate.
  • Analytical/Investigative skills to identify unusual or possible suspicious activity regarding broker-dealer customer transaction or account activities.
  • Knowledge of automated transaction monitoring systems (e.g. Prime BSA Reporter, Oracle Mantas) and other investigative tools (e.g. WorldCheck and others).
  • Working knowledge of Excel, including data analysis

Key requirements:

  • Bachelor’s degree in accounting, business administration, finance, or similar field.
  • Advanced degrees, JD or MBA degree – preferred.
  • A minimum of 5 years’ experience working in a regulatory and/or compliance, law enforcement or other investigative capacity within a broker-dealer and/or financial institution setting.
  • Working knowledge of U.S. Capital Markets and current regulatory environment in the financial service industry.
  • Extensive knowledge of FINRA broker-dealer rules, including those related to AML/OFAC.
  • Strong institutional brokerage and investment advisory product knowledge – preferred.
  • Series 7 required and Series 24 preferred.
  • Member of SIFMA AML Committee – preferred.
  • Regulatory experience - preferred but not required

If you require any more information please contact Gregory Pallay: or (646) 618 8862

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