BSA High Risk Analyst

The pay range represents the anticipated base pay for this position. Actual pay will be based on factoring including, but not limited to: market data, internal equity, skillset and knowledge, experience, education and overall qualifications for the role.

This position is eligible for a hybrid work schedule.

Primary Location: St. Cloud, MN (Bloomington, MN available as an alternate worksite)

JOB SUMMARY

The BSA High Risk Analyst is responsible for the oversight, administration, and ongoing monitoring of the Bank’s high-risk customer portfolio, with primary responsibility for the marijuana banking program. This position supports the Bank’s compliance with all applicable laws and regulations related to Bank Secrecy Act (BSA), Anti-Money Laundering (AML), Office of Foreign Assets Control (OFAC), FinCEN guidance, and internal policies and procedures.

The analyst performs enhanced due diligence (EDD), transaction monitoring, risk assessments, suspicious activity investigations, and periodic reviews for high-risk customers and business types. This role works closely with Retail Banking, Treasury Management, Deposit Operations, Lending, Compliance, and Executive Management to ensure high-risk relationships are appropriately onboarded, monitored, and managed.

JOB RESPONSIBILITIES

1. Marijuana Banking Program Administration

• Administer and oversee the Bank’s marijuana banking program, including onboarding, due diligence, monitoring, and ongoing compliance reviews.
• Conduct enhanced due diligence for marijuana-related businesses (MRBs), including:
  • Beneficial ownership verification
  • State licensing validation
  • Business structure and ownership reviews
  • Site visit coordination and documentation
  • Source of funds analysis
  • Financial activity analysis
• Monitor customer activity for consistency with expected business operations and documented cash flow.
• Review cash activity, ACH transactions, wires, RDC activity, and account patterns for suspicious or unusual activity.
• Maintain marijuana banking customer files and ensure documentation remains current and complete.
• Prepare and maintain required reporting related to MRB customers, including Suspicious Activity Reports (SARs) and any marijuana-specific SAR narratives.
• Coordinate periodic reviews and risk rating updates for marijuana banking relationships.
• Monitor state and federal regulatory developments impacting marijuana banking activities.

2. High-Risk Customer Oversight

• Perform enhanced due diligence reviews for other high-risk customer categories, including but not limited to:
  • Money Services Businesses (MSBs)
  • Cash-intensive businesses
  • Nonprofit organizations
  • ATM operators
  • Cryptocurrency-related customers
  • Third-party payment processors
  • Foreign businesses or individuals
  • High-risk legal entities
• Conduct periodic account reviews and ongoing monitoring activities.
• Analyze transactional activity to identify unusual patterns, structuring, fraud indicators, or potential money laundering activity.
• Assist with customer risk rating reviews and updates.
• Investigate alerts generated through transaction monitoring systems.

3. BSA/AML Compliance Support

• Prepare, document, and file Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) as needed.
• Support the Bank’s Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) programs.
• Assist with regulatory examinations, internal audits, and independent BSA audits.
• Maintain accurate and organized records supporting investigative decisions and compliance activities.
• Participate in the development and enhancement of BSA policies, procedures, and monitoring processes.
• Assist with training bank staff on high-risk customer identification, marijuana banking requirements, and fraud red flags.

4. Collaboration and Risk Management

• Partner with frontline staff during onboarding of high-risk relationships.
• Provide guidance to business lines regarding account restrictions, monitoring expectations, and risk mitigation strategies.
• Escalate significant compliance concerns, suspicious activity, or policy exceptions to BSA leadership.
• Participate in committees or working groups related to fraud, compliance, and operational risk.

JOB REQUIREMENTS

Education-

• Required: High School diploma
• Preferred: Bachelor’s degree in finance, accounting, criminal justice, business or related field preferred.

Experience-

• 4-6 years of experience in BSA/AML compliance within a financial institution.
• Experience managing or supporting a marijuana banking program strongly preferred.

SCHEDULE

This position is scheduled to work 40 hours per week from 8:30 am to 5:00 pm. The Company reserves the right to change the schedule as required for business needs.

BENEFIT INFORMATION

Our Team Members enjoy a comprehensive benefits package, including:

• Health Insurance with two medical plan options as well as dental and vision options.
• Employer matched 401(k) plan.
• Company-paid life insurance, AD&D and short and long-term disability. Team members can also purchase additional life and AD&D insurances.
• Paid Time Off and all Federal holidays observed.

MidCountry Bank is an equal opportunity employer and does not discriminate against otherwise qualified applicants on the basis of race, color, creed, religion, ancestry, age, sexual orientation, marital status, national origin, disability or handicap, veterans status, genetic information or gender identity. MidCountry Bank is an EEO/AA Employer.