Compliance Manager, BSA/AML Program

The Team:

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.

How you’ll make an impact

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.

Minimum Qualifications

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.

Preferred Qualifications

Certified Anti-Money Laundering Specialist (CAMS), Certified AML and Fraud Professional (CAFP), or equivalent certification.

Experience supporting deposit products, including high-yield savings accounts, certificates of deposit, brokered deposits, or similar banking products.

Familiarity with implementing BSA/AML tools for transaction monitoring, case management, and customer screening

Experience working with examiners, auditors, and other third-parties.

Knowledge of regulatory change management and implementing new BSA/AML requirements.

Ability to investigate complex compliance issues, perform root cause analysis, and provide guidance to support issue resolution

Position location This role is available in the following locations: Remote

Time zone requirements The team operates on the East/West coast time zones.

Travel requirements As a digital first company, the majority of your work can be accomplished remotely. The majority of our employees can live and work anywhere in the U.S but are encouraged to to still spend high quality time in-person collaborating via regular onsites. The in-person sessions’ cadence varies depending on the team and role; most teams meet once or twice per quarter for 2-4 consecutive days at a time.

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At Upstart, your base pay is one part of your total compensation package.  The anticipated base salary for this position is expected to be within the below range. Your actual base pay will depend on your geographic location–with our “digital first” philosophy, Upstart uses compensation regions that vary depending on location. Individual pay is also determined by job-related skills, experience, and relevant education or training. Your recruiter can share more about the specific salary range for your preferred location during the hiring process.

In addition, Upstart provides employees with target bonuses, equity compensation, and generous benefits packages (including medical, dental, vision, and 401k).

United States | Remote - Anticipated Base Salary Range

$115,800—$160,100 USD