Compliance Manager, Upstart

• Bachelor's degree or equivalent practical experience
• 7+ years of experience in BSA/AML compliance, financial crimes compliance, or a related Risk or Compliance role within a bank or other regulated financial institution
• Experience implementing and managing customer onboarding processes including identity verification, customer due diligence (CDD), enhanced due diligence (EDD), sanctions screening, and ongoing monitoring processes
• Working knowledge of regulatory requirements, including the Bank Secrecy Act (BSA), USA PATRIOT Act, and Customer Due Diligence Rule, and BSA/AML risks associated with deposit products
• Experience developing and delivering AML risk assessments, KRIs/KPIs, and management reporting while leading cross-functional compliance initiatives
• Strong organizational, analytical, communication skills
• Ability to identify gaps in policies and procedures and drive resolution and closure
• Experience in audit and exam readiness, including evidence gathering, testing and monitoring, addressing findings, responding to requests

Desirable

• Upstart's Bank Secrecy Act/Anti-Money Laundering Compliance team is responsible for designing, implementing, and overseeing the company's enterprise BSA/AML Program, Customer Identification Program (CIP), Customer Due Diligence (CDD), sanctions, and suspicious activity compliance programs
• We partner closely with Product, Engineering, Operations, Legal, Fraud, and Enterprise Risk to ensure our products and services are built on a strong foundation of regulatory compliance and effective risk management
• We build scalable, risk-based programs that evolve alongside our products and regulatory expectations
• As the Compliance Manager, BSA/AML Program at Upstart, you will serve as a BSA/AML subject matter expert for Upstart Bank’s secured and unsecured lending products and support the development of new deposit products
• Using a risk-based approach, you will evaluate changes to identify risks, develop controls, and measure ongoing performance of changes to ensure products and services are implemented within a strong compliance framework
• Lead the design, execution, and continuous improvement of BSA/AML, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), transaction monitoring, and sanctions screening processes for secured lending, unsecured lending, and deposit account products
• Serve as a BSA/AML Compliance advisor for deposit product initiatives, partnering with Product, Legal, Operations, Engineering, and Enterprise Risk throughout product development and implementation
• Develop and manage BSA/AML compliance initiatives, including new deposit product launches, regulatory enhancements, and control improvements
• Administer ongoing customer due diligence and enhanced due diligence programs for deposit accounts in alignment with Upstart's Customer Identification Program (CIP), Red Flags Program, and BSA/AML compliance procedures
• Evaluate relevant risks and typologies to develop appropriate transaction monitoring rules and efficient investigations processes
• Monitor evolving regulatory requirements, including FinCEN guidance, OFAC sanctions, and FFIEC BSA/AML examination expectations, to translate regulatory changes into scalable business processes and controls
• Develop key risk indicators (KRIs), key performance indicators (KPIs), and management reporting that provide actionable insights into BSA/AML program effectiveness
• Translate regulatory requirements and risk trends into clear recommendations for business stakeholders and senior leadership
• Drive remediation efforts for examination, audit, monitoring, and testing findings while strengthening the overall BSA/AML compliance control environment