Job Title:AML/KYC Analyst – US Correspondent Banking Compliance
Location: MGN, India (MBNY’s dedicated team)
Department: BSA/AML & Sanctions Compliance, Mashreq Bank, New York (“MBNY”)
Reports To: To be decided
Job Summary
The AML/KYC Analyst is responsible for executing end‑to‑end AML and KYC controls for foreign correspondent bank relationships within a U.S. intermediary bank. The role includes performing Customer Identification Program (CIP) procedures, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), Adverse Media Screening, and Transaction Monitoring Investigations to identify, assess, and mitigate money laundering, terrorist financing, sanctions, and other financial crime risks. The analyst applies a risk‑based approach in compliance with U.S. regulatory requirements and MBNY internal policies.
Key Responsibilities
KYC & Customer Identification (CIP)
- Perform CIP verification for foreign correspondent banks in accordance with the USA PATRIOT Act and internal onboarding standards
- Validate:
- Legal existence, licensing, and regulatory status
- Physical presence and shell bank prohibitions
- Authorized signatories and key management
- Ensure accurate documentation and data integrity across KYC system
Customer Due Diligence (CDD)
- Conduct initial and periodic CDD reviews for foreign correspondent banking relationships
- Analyze:
- Ownership and control structure
- Board and senior management
- Nature of business, products, services, and customer base
- Geographic exposure and high‑risk jurisdictions
- Complete customer risk assessments, clearly documenting risk drivers and mitigating controls
Enhanced Due Diligence (EDD) – Correspondent Banking
- Perform EDD reviews for high‑risk correspondent banks in compliance with PATRIOT Act Section 312
- Assess the respondent bank’s:
- AML, sanctions, and transaction monitoring framework
- Regulatory history, enforcement actions, and audit findings
- Use of payable‑through accounts (PTAs)
- Nested or downstream correspondent relationships
- Review and analyze Wolfsberg Correspondent Banking Due Diligence Questionnaire (CBDDQ) responses
- Develop detailed EDD narratives with clear conclusions and risk acceptance recommendations
Adverse Media & Screening
- Conduct and analyze:
- Adverse/negative news screening
- Sanctions screening (OFAC and other relevant lists)
- PEP and high‑risk association checks
- Assess credibility, severity, and relevance of adverse information
- Escalate material findings, red flags, and reputational risks to AML Management
Transaction Monitoring & Investigations
- Review and investigate transaction monitoring alerts related to correspondent banking activity, including:
- Cross‑border wire transfers
- High‑risk corridors and jurisdictions
- Unusual volumes, patterns, or payment flows
- Perform detailed investigations using internal systems and supporting documentation
- Determine whether alerted activity is questionable and prepare narratives
Risk Escalation & Governance
- Identify and escalate:
- Control gaps at respondent banks
- Significant changes in risk profile
- Potential sanctions or regulatory exposure
Regulatory, Audit & Exam Support
- Ensure full alignment with:
- Bank Secrecy Act (BSA)
- FinCEN CDD Rule
- FFIEC BSA/AML Examination Manual
- OFAC sanctions requirements
Stakeholder Collaboration
- Work closely with:
- MBNY KYC Team
- MBNY Sanctions Team
- AML Investigations and SAR teams
Experience
- 4-5 years of AML/KYC experience, with strong focus on foreign correspondent banking
- Experience within a U.S. bank or U.S. branch/agency of a foreign bank preferred
- Deep knowledge of:
- Correspondent banking risk typologies
- Cross‑border payment flows and clearing activity
- Nested correspondent and PTA risks
- CIP, CDD, and EDD execution
- Transaction monitoring alert investigations
- SAR drafting and decisioning
- Wolfsberg CBDDQ and risk rating methodologies
Preferred Qualifications
- CAMS, CFE, or equivalent AML certification
The leading financial institution in MENA
While more than half a century old, we proudly think like a challenger, startup, and innovator in banking and finance, powered by a diverse and dynamic team who put customers first. Together, we pioneer key innovations and developments in banking and financial services. Our mandate? To help customers find their way to Rise Every Day, partnering with them through the highs and lows to help them reach their goals and unlock their unique vision of success. Delivering superior service to clients by leading with innovation, treating colleagues with dignity and fairness while pursuing opportunities that grow shareholders value. We actively contribute to the community through responsible banking in our mission to inspire more people to Rise.