Vice President – Financial Crimes Independent Testing and Quality Assurance

About the Role:

The Vice President, Financial Crimes Independent Testing and Quality Assurance is responsible for leading and overseeing the organization's Financial Crimes Independent Testing and Quality Assurance Program across BSA/AML, Sanctions, Fraud, and related Financial Crimes Compliance activities.

This role provides strategic leadership and independent oversight of the design, implementation, execution, and effectiveness of Financial Crimes processes and controls across the First Line of Defense (1LoD) and Second Line of Defense (2LoD). The VP is responsible for establishing and maintaining a comprehensive, risk-based Independent Testing and Quality Assurance framework designed to evaluate whether Financial Crimes activities are operating effectively, consistently, and in accordance with regulatory expectations, internal policies, procedures, and established risk management standards.

The VP will oversee the Financial Crimes QA Manager and QA team and will be accountable for the overall strategy, governance, methodology, planning, execution, reporting, and continuous improvement of the Independent Testing and QA Program.

The role will provide independent and credible challenge to Financial Crimes leadership and stakeholders by identifying control weaknesses, execution deficiencies, governance gaps, systemic issues, and emerging risks. The VP will work collaboratively across business lines, Financial Crimes Compliance, Risk Management, Technology, Model Risk Management, and Internal Audit to strengthen the organization's Financial Crimes control environment and overall risk management framework.

What You Will Do:

Independent Testing and Quality Assurance Program Leadership

• Own and lead the enterprise Financial Crimes Independent Testing and Quality Assurance Program.
• Establish the strategic vision, governance framework, operating model, and standards for independent testing and QA activities.
• Develop and maintain a comprehensive, risk-based testing universe covering Financial Crimes processes, risks, controls, and activities across 1LoD and 2LoD.
• Establish a risk-based annual and ongoing testing plan based on factors including:
• Inherent Financial Crimes risk, regulatory exposure, control complexity and criticality, customer, product, service, and geographic risk, transaction volumes, prior findings and control performance, regulatory and audit findings, emerging risks and typologies, and material changes to systems, processes, products, or organizational structures
• Ensure appropriate testing coverage across BSA/AML, Sanctions, Fraud, Customer Due Diligence, Transaction Monitoring, Customer Risk Rating, Suspicious Activity Reporting, and other Financial Crimes activities, as applicable.
• Ensure testing and QA activities remain appropriately independent from the processes and controls being reviewed.

First & Second Line of Defense Independent Testing and Quality Assurance

Oversee the independent testing of key 1LoD and 2LoD Financial Crimes processes and controls, including, as applicable:

• Risk Assessment
• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
• Customer onboarding and Know Your Customer (KYC) activities
• Transaction Monitoring alert investigation and disposition
• Suspicious Activity Report (SAR) escalation and decision-making
• Sanctions screening, investigation, and disposition
• Fraud detection and investigation activities
• Customer Risk Rating execution
• High-risk customer management
• Periodic and event-driven customer reviews
• Financial Crimes operational procedures and controls
• Financial Crimes Oversight and governance forum activities, including escalations, issue management, change management, metrics and reporting
• Data quality and key Financial Crimes data processes

Testing should evaluate, as applicable:

• Control design and implementation, operating effectiveness, accuracy and completeness, quality, timeliness, sustainability, evidentiary support, and appropriateness of disposition and escalation decisions

The role should maintain the distinction between assessing 1LoD execution deficiencies and evaluating 2LoD oversight or governance deficiencies, consistent with the underlying QA framework.

Testing Framework and Methodology Development

• Establish and maintain standardized methodologies for Financial Crimes Independent Testing and Quality Assurance.
• Own testing standards, procedures, and minimum documentation requirements.
• Approve and/or oversee the development of:
• Risk assessments, test plans, test scripts, sampling methodologies, workpaper standards, QA scoring frameworks, defect taxonomies, issue severity methodologies, and reporting standards
• Establish risk-based sampling methodologies based on population size, risk, complexity, materiality, prior performance, and control effectiveness.
• Define clear standards for evaluating:
• Control design effectiveness and implementation, operating effectiveness, execution quality, governance effectiveness, and oversight effectiveness
• Ensure methodologies differentiate among individual errors, process deficiencies, control failures, systemic weaknesses, and governance deficiencies.
• Establish calibration and quality control processes to promote consistency across testers and reviewers.

The existing Manager role provides the operational foundation for methodologies involving test scripts, defect taxonomies, scoring frameworks, and risk-based sampling; the VP should own the enterprise framework and governance surrounding those methodologies.

QA and Testing Execution Oversight

• Oversee the execution of the Independent Testing and QA Plan by the Financial Crimes QA Manager and QA team.
• Ensure testing is performed consistently, objectively, and in accordance with approved methodology.
• Review significant testing results, findings, and thematic observations.
• Challenge testing conclusions where appropriate to ensure findings are well-supported, risk-based, and consistently applied.
• Ensure appropriate documentation of testing procedures, evidence, conclusions, and findings.
• Monitor testing progress, resource capacity, and completion against established plans and timelines.
• Escalate significant testing delays, resource constraints, or coverage gaps to appropriate management.

Thematic and Horizontal Reviews

• Lead and oversee thematic and horizontal testing across Financial Crimes functions, processes, products, and business areas.
• Identify systemic weaknesses, recurring deficiencies, and emerging trends across 1LoD and 2LoD activities.
• Analyze trends involving control failures, quality deficiencies, missed escalations, inconsistent decision-making, policy interpretation, governance effectiveness, and repeat findings
• Initiate targeted reviews in response to significant events, emerging Financial Crimes risks, regulatory developments, internal incidents, or adverse performance trends.
• Provide senior management with insights regarding systemic risks and potential control blind spots.

Issue Management and Remediation Validation

• Establish and oversee the Financial Crimes Independent Testing and QA issue management framework.
• Ensure findings clearly articulate the deficiency identified, impacted process or control, root cause, risk and regulatory impact, severity, and required corrective action
• Approve severity ratings for significant or material findings.
• Establish escalation protocols for high-risk and systemic issues.
• Monitor management action plans and remediation commitments.
• Oversee independent validation of remediation to determine whether corrective actions effectively address the underlying issue and root cause.
• Identify repeat findings and escalate unresolved or recurring issues to senior management and governance committees.
• Maintain appropriate independence from remediation ownership.

The Manager-level role currently includes documenting findings, root cause analysis, severity ratings, management reporting, and remediation validation; the VP should establish the governance and escalation framework for these activities.

Reporting and Governance

• Develop and maintain executive-level reporting for the Independent Testing and QA Program.
• Provide regular reporting to senior management and Financial Crimes governance committees regarding:
• Testing coverage and completion
• QA results and trends
• Significant findings
• Repeat and systemic issues
• Control effectiveness
• Emerging risks
• Remediation status
• Program performance metrics
• Establish Key Performance Indicators (KPIs) and Key Risk Indicators (KRIs) for the Independent Testing and QA Program.
• Ensure significant issues are appropriately escalated through established governance channels.
• Provide executive-level insight into the overall effectiveness and maturity of the Financial Crimes control environment.

Stakeholder Engagement and Credible Challenge

• Provide independent and credible challenge to Financial Crimes management, business leadership, and other stakeholders.
• Partner with stakeholders while maintaining appropriate independence and objectivity.
• Establish strong working relationships with key stakeholders
• Coordinate with Internal Audit to promote alignment of assurance coverage while maintaining clear distinctions between 2LoD Independent Testing and 3LoD Internal Audit responsibilities.
• Support regulatory examinations by demonstrating the rigor, independence, and effectiveness of the Independent Testing and QA Program

The current QA specification appropriately emphasizes credible challenge, partnership with Model Risk Management and Internal Audit, and demonstrating the effectiveness of QA practices during examinations.

Continuous Improvement

• Continuously assess the effectiveness and maturity of the Independent Testing and QA Program.
• Identify opportunities to improve testing methodologies, tools, analytics, automation, and reporting.
• Leverage data analytics to identify anomalies, trends, control weaknesses, and areas requiring targeted testing.
• Monitor regulatory developments, enforcement actions, industry practices, and emerging Financial Crimes risks.
• Ensure the Independent Testing and QA Program evolves in response to changes in the organization's risk profile.
• Promote training, calibration, and knowledge sharing across the QA and Independent Testing team.

Team Leadership

• Provide direct leadership and oversight of the Financial Crimes QA Manager.
• Oversee the broader Financial Crimes QA and Independent Testing team.
• Establish clear roles, responsibilities, and accountability across the team.
• Set strategic priorities, performance expectations, and annual objectives.
• Ensure adequate staffing, technical expertise, and capacity to execute the Independent Testing and QA Plan.
• Develop and mentor team members and support succession planning.
• Ensure consistent application of testing methodology and standards across the team.

The Manager role is structured to lead QA analysts and oversee planning, execution, and reporting; the VP should provide the strategic leadership and program ownership above that operational layer.

Experience

Required

• Bachelor's degree in Finance, Business, Risk Management, Compliance, Accounting, or related field.
• 10–15+ years of progressive experience in Financial Crimes, BSA/AML, Sanctions, Fraud, Risk Management, Compliance, Quality Assurance, Compliance Testing, Internal Audit, or related functions.
• Significant experience leading Financial Crimes QA, independent testing, compliance testing, audit, or assurance programs.
• Demonstrated experience evaluating Financial Crimes processes and controls across operational and compliance functions.
• Strong knowledge of regulatory requirements, FCRM, internal control frameworks, control design and operating effectiveness testing, QA and independent testing methodologies, three lines of defense frameworks, and governance, issue management, and remediation.
• Experience leading teams and managing complex testing or assurance programs.
• Experience providing credible challenge to senior management and stakeholders.
• Strong analytical, strategic, and judgment capabilities.

Preferred

• CAMS, CFE, CRCM, CIA, CPA, or similar professional certification.
• Experience with Transaction Monitoring, Customer Risk Rating, CDD/KYC, sanctions screening, or Financial Crimes technology platforms.
• Experience with NICE Actimize or similar Financial Crimes systems.
• Experience with Financial Crimes model governance.
• Experience supporting regulatory examinations and remediation programs.
• Experience developing enterprise-level testing methodologies and risk-based testing plans.
• Experience leveraging data analytics, automation, and reporting tools.

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

Salary range: $125,000– $208,000

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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