Financial Crimes Risk Management Customer Due Diligence - Enhanced Due Diligence and Know Your Customer Program Manager

Location:

4900 Tiedeman Road, Brooklyn Ohio

Job Summary
The Senior Compliance Officer serves as the enterprise subject matter expert and senior second-line compliance authority for the Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Know Your Customer (KYC) frameworks. This role provides enterprise-wide governance, oversight, credible challenge, and strategic guidance to help ensure related processes, procedures, standards, controls, systems, data, and supporting documentation are appropriately designed, implemented, maintained, and operating effectively. The Senior Compliance Officer partners across the first, second, and third lines of defense to identify regulatory risk, assess related control coverage and design, resolve complex matters, drive sustainable remediation, and promote consistent execution across all applicable legal entities, businesses, products, channels, and customer segments.

Essential Functions

• Serve as the enterprise subject matter expert for CIP, CDD, EDD, KYC, beneficial ownership, customer risk rating, customer lifecycle management, and related regulatory requirements and industry practices. Including reviewing/approving/denying cases/records/escalations.
• Execute risk oversight activities in accordance with the FCRM governance framework, related standards, and requirements.
• Provide second-line oversight and credible challenge of all enterprise-wide processes, procedures, controls, systems, tools, data, and operational practices supporting customer identification, verification, due diligence, risk classification, enhanced review, onboarding, periodic review, trigger-based review, and customer exit.
• Interpret applicable laws, rules, regulatory guidance, examination expectations, and enforcement themes; assess enterprise impact; and translate requirements into clear policies, standards, control expectations, and implementation guidance.
• Own or provide authoritative review and approval of enterprise policies and standards for CIP, CDD, EDD, and KYC, and oversee the governance of supporting first-line procedures and job aids.
• Evaluate whether controls are appropriately designed to mitigate inherent and residual risks and whether control execution is effective, consistent, evidenced, and sustainable across the enterprise.
• Identify gaps, emerging risks, inconsistent practices, control weaknesses, and potential regulatory exposure; communicate the risk clearly; and require timely corrective action or formal risk acceptance, as appropriate.
• Support enterprise risk assessments, including BSA/AML risk assessments, regulatory compliance risk assessments, risk and control self-assessments, customer risk methodologies, and topical assessments related to CIP, CDD, EDD, and KYC.
• Define and monitor risk appetite, risk tolerance, key risk indicators, key performance indicators, control metrics, quality results, exceptions, backlogs, aging, and other management information used to assess program health.
• Review and challenge business process risk identification, new or modified products and services, customer journeys, delivery channels, acquisitions, integrations, third-party arrangements, and material changes that may affect CIP, CDD, EDD, or KYC obligations.
• Provide senior compliance guidance on complex, high-risk, novel, or escalated customer matters, including high-risk customer acceptance, due diligence sufficiency, beneficial ownership, documentation exceptions, risk-rating disputes, remediation, restriction, and exit considerations.
• Partner with Legal, BSA/AML leadership, sanctions, business compliance, operations, technology, data, model risk, fraud, privacy, third-party risk, Internal Audit, and independent testing teams to promote an integrated and consistent control environment.
• Oversee, develop, or provide credible challenge to quality assurance, compliance monitoring, independent testing, internal audit, and regulatory examination activities; assess results, identify systemic themes, and track management response.
• Provide subject matter leadership for regulatory examinations, audits, inquiries, and information requests, including preparation of narratives, evidence, issue responses, and presentations to senior management or governance committees.
• Oversee issue identification, severity assessment, root-cause analysis, corrective-action design, validation readiness, risk acceptance, and sustainable closure for CIP, CDD, EDD, and KYC matters.
• Provide compliance oversight of data governance, data lineage, data quality, record retention, system functionality, automated decisioning, rules, models, and technology changes supporting the KYC lifecycle.

• Establish enterprise training requirements and provide or oversee targeted training, communications, implementation materials, and subject matter support for affected employees and stakeholders, in accordance with the FCRM Governance Framework standards and requirements.
• Prepare and present concise reporting on risk exposure, program effectiveness, control performance, significant issues, emerging risks, and remediation status to senior management, governance committees, and the Board, as appropriate.
• May lead, develop, and supervise a team of compliance professionals, including setting priorities, assigning work, managing performance, providing coaching and feedback, and supporting talent development and succession planning; lead cross-functional initiatives and working groups; and promote consistent interpretation and application of enterprise requirements.
• Maintain current knowledge of regulatory developments, enforcement actions, peer practices, and evolving financial crime risks, and recommend enhancements to the enterprise compliance program.
  

Education

• Bachelor’s degree or equivalent combination of education and relevant experience.
• Extensive experience in BSA/AML, financial crimes compliance, regulatory compliance, KYC operations, risk management, Legal, Internal Audit, or a related discipline within a financial institution.
• Deep knowledge of CIP, CDD, EDD, beneficial ownership, customer risk rating, customer lifecycle management, and risk-based compliance program expectations.
• Demonstrated ability to interpret regulatory requirements and translate them into enterprise policies, standards, controls, governance routines, and practical business guidance.
• Experience evaluating complex processes and control environments, identifying systemic risk, and influencing sustainable corrective action.
• Strong executive communication, facilitation, negotiation, and written documentation skills, with the ability to explain complex risk matters clearly and concisely.
• Demonstrated ability to lead cross-functional initiatives, influence senior stakeholders, and provide credible challenge in a complex, highly regulated environment.

Work Experience

• 7+ years of federal law enforcement or U.S. Intelligence Community experience (veterans encouraged to apply) (preferred)
• 3+ years of management experience (preferred)
• Extensive experience in financial crimes investigations (preferred)

Preferred Qualifications

• Advanced degree in law, business, finance, risk management, criminal justice, or a related field.
• Professional certification such as CAMS, CFE, CRCM, CFCS, or a comparable compliance or financial crimes credential.
• Experience with large or complex financial institutions, multiple lines of business, enterprise transformation, regulatory remediation, or direct regulatory examination engagement.
• Knowledge of data governance, technology controls, automation, and systems supporting customer onboarding and lifecycle management.

Licenses and Certifications

• CAMS certification (preferred)

Core Competencies

• Enterprise risk leadership and strategic judgment
• Regulatory interpretation and policy governance
• Independent oversight and credible challenge
• Control design and operating-effectiveness assessment.
• Issue management and sustainable remediation.
• Data-driven risk analysis and management reporting
• Executive presence and stakeholder influence
• Cross-functional leadership and change management
• Clear, concise, and defensible documentation
• All KeyBank employees are expected to demonstrate Key’s Values and abide by Key’s Code of Conduct.

Physical Demands

• General Office - Prolonged sitting, ability to communicate face to face in person or on the phone with teammates and clients, frequent use of PC/laptop, occasional lifting/pushing/pulling of backpacks, computer bags up to 10 lbs.

Work Location Category

• Hybrid (3+ days)

COMPENSATION AND BENEFITS

This position is eligible to earn a base salary in the range of $96,000.00 - $181,000.00 annually. Placement within the pay range may differ based upon various factors, including but not limited to skills, experience and geographic location. Compensation for this role also includes eligibility for incentive compensation which may include production, commission, and/or discretionary incentives.

Please click here for a list of benefits for which this position is eligible.

Key has implemented an approach to employee workspaces which prioritizes in-office presence, while providing flexible options in circumstances where roles can be performed effectively in a mobile environment.

Job Posting Expiration Date: 11/20/2026

KeyCorp is an Equal Opportunity Employer committed to sustaining an inclusive culture. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, age, genetic information, pregnancy, disability, veteran status or any other characteristic protected by law.

Qualified individuals with disabilities or disabled veterans who are unable or limited in their ability to apply on this site may request reasonable accommodations by emailing [email protected].

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