Governance, risk and compliance

SmartSuite for the Financial Crime Compliance Officer

The Financial Crime Compliance Officer, often the BSA/AML Officer, owns the program that prevents money laundering, sanctions breaches and terrorist financing: the risk assessment, customer due diligence standards, transaction monitoring, suspicious activity reporting and regulator engagement.

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Reports to:

Chief Compliance Officer

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What you own

Maintain the enterprise financial crime risk assessment
Set customer due diligence and enhanced due diligence standards
Oversee transaction monitoring, alert handling and case investigation
File suspicious activity reports and manage regulator engagement
Operate sanctions screening and escalation
Deliver AML training and independent testing coordination
Report program effectiveness to the board

At a glance

The GRC processes this role owns, touches and depends on.

Owns

accountable for the process

compliance

Touches

contributes or approves

risk, issues-actions, reporting, third-party

Depends on

consumes its output

audit, policy

How the GRC processes connect

Three lines of defense set the frame; the chain shows where each process hands off to the next. Colors follow the role: navy is owned, blue is touched, gray is depended on.

Reporting lines

Who this role reports to, who reports to them, and the peers they work with most.

Reports to

Chief Compliance Officer

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Direct reports

Works closely with

How SmartSuite supports this role

Lead

Risk management. Holds the financial crime risk assessment as a scored register by product, customer type, geography and channel.

Compliance management. Maps AML and sanctions obligations to controls and tracks testing and evidence for examinations.

Issues and actions. Manages alerts, investigations and SAR decisions as cases with audit trails and restricted access.

Reporting. Reports program metrics, open cases and examination findings to the board and regulators.

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Products this role uses most

Compliance Assessments & Testing

Manage assessment campaigns and testing schedules with a reusable question library, automated workflows, and one place for evidence collection.

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Enterprise Risk Management (ERM)

Centralize enterprise risk management with standardized assessments, dashboards, and linked workflows that align risk, controls, and mitigation across your organization.

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Issues Management

Track and remediate issues across audits, risk, and compliance with structured workflows, clear ownership, and real-time visibility into resolution status.

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Regulatory Inquiries

Manage regulatory requests and exams with response workflows, evidence on each inquiry record, and visibility into status and deadlines.

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Control Framework & Regulatory Libraries

Keep controls in one library and map them across frameworks to reduce duplication and enable a test-once, comply-many approach.

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Industry reference

The Bank Secrecy Act and FinCEN's rules (31 CFR Chapter X), as amended by the AML Act of 2020, define the program: a risk assessment, customer due diligence, transaction monitoring, suspicious activity reporting and independent testing. The FFIEC BSA/AML Examination Manual is the examiner's checklist; OFAC rules govern sanctions screening. The FATF Recommendations set the international baseline, implemented in the EU's AML package and the UK's Money Laundering Regulations.

The role is concentrated in banking, broker-dealers (FINRA Rule 3310), money services businesses, insurers and crypto-asset firms, with lighter duties for designated non-financial businesses such as real estate and legal services.

Related roles

Chief Compliance Officer

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DEEPEN YOUR KNOWLEDGE

Explore Further

Guides and definitions from the GRC Knowledge Center and the What-is glossary, chosen for this role.

All articles

What's new

What is a Risk Assessment Framework?

What is RCSA?

SOC 2 Audit Timeline: Readiness, the Observation Window and Bridge Letters

What Good GRC Evidence Looks Like for Regulators, Auditors, and Customers

How to Reduce Duplicate Evidence Requests Across GRC Teams

SOC 2 Compliance as a Connected Workflow, Not a Scramble

Compliance Assessments and Testing

Frequently asked questions

What does a Financial Crime Compliance Officer own?

The Financial Crime Compliance Officer, often the BSA/AML Officer, owns the program that prevents money laundering, sanctions breaches and terrorist financing: the enterprise financial crime risk assessment, customer due diligence and enhanced due diligence standards, oversight of transaction monitoring, alert handling and case investigation, suspicious activity reporting and regulator engagement, sanctions screening and escalation, AML training and the coordination of independent testing. They report program effectiveness to the board. The Bank Secrecy Act, FinCEN's rules and the FFIEC examination manual define what that program must contain.

How does SmartSuite hold a Financial Crime Compliance Officer's risk assessment?

Enterprise Risk Management (ERM) holds the financial crime risk assessment as a scored register by product, customer type, geography and channel, so the inherent and residual risk for each dimension is recorded with its rationale rather than in an annual document. When a new product launches or a geography changes, the affected entries are updated and the assessment stays current between the annual refreshes examiners expect. The Fraud Risk Manager maintains the fraud entries in the same register, so overlapping schemes are visible.

How are AML and sanctions obligations mapped to controls for examinations?

SmartSuite maps AML and sanctions obligations to controls and tracks the testing and evidence for examinations, with the obligations held in Control Framework & Regulatory Libraries and the tests run in Compliance Assessments & Testing. The Financial Crime Compliance Officer can show an examiner the control that satisfies each FinCEN, OFAC or FINRA Rule 3310 obligation, when it was last tested and the evidence. The Internal Auditor's independent testing draws on the same records, which is what the examination manual expects.

How does SmartSuite manage alerts, investigations and SAR decisions?

Issues Management holds escalated alerts, investigations and SAR decisions as records with owners, audit trails and role-based access, so each escalated alert becomes a record with its investigation steps, the decision to file or not file and the reasoning, visible only to the team assigned. The Compliance Analyst works the cases and the Financial Crime Compliance Officer reviews decisions from the same record. SmartSuite is the case and program record around your monitoring and screening systems rather than a replacement for them.

How does a Financial Crime Compliance Officer report to the board and regulators?

SmartSuite reports program metrics, open cases and examination findings to the board and regulators from the register, the control tests and the case records, so the Chief Compliance Officer and the board see alert and case volumes, time to decision, testing status and open examination findings from the live program. Regulatory Inquiries holds examiner requests and responses, with the Regulatory Affairs Manager and the General Counsel working in the same record. Findings from an examination are tracked to remediation with owners.

How does a financial crime program get started in SmartSuite?

Load the current risk assessment by product, customer type, geography and channel, the obligation set for the regimes you are examined under and the control list with its testing calendar; open cases and examination findings can be loaded or started fresh. The first examination cycle run from SmartSuite gives the examiner the traceable record they look for. The Fraud Risk Manager, the Internal Auditor and the Compliance Analyst work in the same records, so independent testing and investigations draw on one source.

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