Bank Secrecy Act Officer (Remote) at PayPal

Job Summary:

The Bank Secrecy Act (BSA) Officer will serve as PayPal Bank’s (PPB) program owner and accountable executive for establishing, implementing, and sustaining the bank’s AML/CFT/OFAC compliance framework suitable for a de novo FDIC-insured ILC. This role will build the program from the ground up to support charter-readiness, ensure effective identification and mitigation of financial crime risks (including AML/CFT, USA PATRIOT Act, OFAC, and CIP/CDD), and deliver strong governance and reporting to PPB senior management and the Board. The Officer will also lead day-to-day program execution and ensure the Bank is continuously exam-ready through robust monitoring, high-quality regulatory reporting, and strong issue remediation. In this role, the BSA Officer will report to the ILC’s Chief Risk Officer (“CRO”).

Essential Responsibilities:

• Establish overall business and technical strategies for entity management that significantly impact PayPal operations.
• Advise on complex legal and regulatory compliance issues related to corporate structures.
• Influence executive-level decision-making through strategic insights and recommendations.
• Ensure the efficient operation of the organization’s diverse entities by maintaining compliance with laws and regulations.
• Lead initiatives that promote effective governance and risk management across the organization.

Key Responsibilities:

• Own and administer the Bank’s AML/CFT/OFAC program, including program design, customer risk profiles, risk assessments, internal controls, customer identification, due diligence, and trainings.
• Lead enterprise AML/CFT/OFAC risk assessment activities and drive risk-based controls to mitigate identified risks.
• Oversee financial crime monitoring and investigations governance, including alert management standards, case documentation, and escalation of emerging issues to senior management.
• Ensure timely, accurate regulatory reporting and program operations (e.g., SAR/CTR governance, exemptions, and supporting documentation standards).
• Establish and maintain a comprehensive training program for employees and Board members on AML/CFT/OFAC obligations.
• Manage issue identification, tracking, and remediation tied to internal QA, independent testing/audit, and regulatory exams, with clear reporting to governance forums.
• Ensure effective oversight of any outsourced/affiliate-provided AML operations and technology, including performance metrics, quality controls, and SLA adherence (where applicable).
• Engage with internal audit and external regulators where required to represent the program.

De Novo Charter Formation & ILC Buildout:

• Stand up PPB’s foundational AML/CFT/OFAC program artifacts for FDIC and state charter review: program charter, policies, procedures, governance cadence, and control inventory.
• Design the initial AML/CFT risk assessment approach aligned to the proposed business model, products, delivery channels, and customer types, and ensure controls scale with growth.
• Define the Bank’s core compliance program components (CIP, CDD/EDD, OFAC screening, transaction monitoring, investigations/SAR governance, recordkeeping) and ensure build-out aligns to regulatory expectations for a new bank.
• Develop first-line and second-line operating model, including staffing plan, role delineation, training plan, and vendor/technology implementation roadmap.
• Establish initial management and Board reporting packages (metrics, KRIs, issues, model/threshold changes, training completion, audit/exam readiness, and risk appetite thresholds / triggers).

Ongoing Program Leadership (Post Opening):

• Operate and continuously enhance the AML/CFT/OFAC program using a risk-based approach, including periodic updates to risk assessments, policies, procedures, and monitoring rules.
• Oversee ongoing operational processes (e.g., SAR/CTR program governance, exemptions, investigative standards, QA/quality control) and ensure consistent documentation and defensibility.
• Maintain and mature the training program for employees and the Board at least annually, and as risk, products, and regulations evolve.
• Lead continuous improvement through monitoring, QA, and independent testing readiness; ensure timely remediation of findings and sustained closure.
• Own program change management, including new products, new customer segments, technology changes, and material threshold/rule adjustments with governance approvals as required.

Regulator Engagement & Exams:

• Serve as PPB’s primary point of contact for AML/CFT/OFAC matters with the FDIC and other relevant supervisors; coordinate responses, meetings, and submissions.
• Lead examination preparedness and execution: pre-exam self-assessments, evidence production, interview readiness, and on-site/virtual exam management.
• Coordinate independent testing/audit activities and ensure audit/exam findings are tracked, escalated appropriately, and remediated with effective corrective action.
• Provide clear governance updates to PPB management and Board committees on program effectiveness, key risks, and remediation status.

Culture, Training & Change Leadership:

• Drive a strong “tone from the top” culture focused on bank employees and PayPal Inc. stakeholder engagement related to their responsibility of detecting and appropriately reporting financial crimes.
• Support development of the bank’s risk culture by ensuring timely and relevant AML/CFT/OFAC trainings are delivered and completed.

Governance & Reporting Lines:

• Primary reporting: ILC Chief Risk Officer
• Governance reporting: Risk and Compliance Committee and Board
• Partnerships: All PPB executive leaders and PayPal Inc. stakeholders where oversight is required

Expected Qualifications:

• 10+ years relevant experience and a Bachelor’s degree OR Any equivalent combination of education and experience.

Required Qualifications:

• Education: Bachelor’s degree in business, finance, economics, accounting, or a related discipline (or equivalent combination of education and experience).
• Experience (Director-level):
• 10+ years in BSA/AML/CFT and financial crimes compliance within a bank or regulated financial institution, including demonstrated program leadership and governance experience.
• Demonstrated ownership of core AML/CFT/OFAC components (risk assessments, training, monitoring/controls, reporting governance, issue remediation).
• Strong ability to build and operationalize policies/procedures and lead cross-functional implementation across Compliance, Operations, Product, Technology, and Risk.
• Demonstrated ability to develop and deliver Board/Executive reporting and to drive remediation of audit/exam findings.

Preferred Qualifications:

• CAMS (ACAMS) or equivalent AML Fraud / Financial Crimes certification.
• Prior experience as a designated BSA Officer/AML Officer for a bank or ILC (or as a deputy with clear accountability for program execution).
• Experience building or transforming AML programs in fast-growth, digital-first, or partner/embedded-finance environments (including vendor/tool selection and operating model design).
• Hands-on experience developing and delivering institution-wide AML/CFT/OFAC training programs, including Board training.
• Deep familiarity with SAR/CTR governance and documentation expectations, including CTR exemptions and investigative file quality standards.

Compensation:

The base pay for this role will depend on where you work and the relevant experience and expertise you bring. The expected range of pay for this role by location is:

Primary Location | Pay Range:

Utah - (Virtual) | ($152,500.00 - $226,600.00 Annually)

Additional Location(s) | Pay Range:

San Jose, California | ($176,500.00 - $262,350.00 Annually)

Additional compensation for this role may include an annual performance bonus, equity, or other incentive compensation, as applicable.

Our Ways of Working:

For most employees, PayPal's balanced hybrid work model offers 3 days in the office for effective in-person collaboration and 2 days at your choice of either the PayPal office or your home workspace, ensuring that you equally have the benefits and conveniences of both locations. Travel of ~ 15% may be required based on business needs for regulatory agency visits, Board meetings, and other key partner / vendor meetings.

Our Benefits:

At PayPal, we’re committed to building an equitable and inclusive global economy. And we can’t do this without our most important asset-you. That’s why we offer comprehensive, choice-based programs, to support all aspects of personal wellbeing—physical, emotional, and financial—delivering meaningful value where it matters most. We strive to create a flexible, balanced work culture with a holistic approach to benefits, including generous paid time off, healthcare coverage for you and your family, and resources to create financial security and support your mental health.