Vice President – Financial Crimes Independent Testing and Quality Assurance

We are a hybrid, remote-office company dedicated to growing our talent anywhere!

We have onsite locations in: Sioux Falls, SD, Phoenix, AZ, Louisville, KY, Troy, MI, Franklin, TN, Easton, PA.

At Pathward, we take tremendous pride in our purpose to create financial inclusion for all™. We are a financial empowerment company that works with innovators to increase financial availability, choice, and opportunity for all. We strive to remove barriers that traditional institutions put in the way of financial access, and promote economic mobility by providing responsible, secure, high quality financial products.

We are a team of problem solvers and innovators who celebrate our differences and know that our unique perspectives make us stronger and well-positioned for success. We celebrate, and embrace, our team members through our *HUMBLE*HUNGRY*SMART approach, and we believe that we are strongest when we embrace the voices of our employees, customers, partners, and the communities we serve.

About the Role:

The Vice President, Financial Crimes Independent Testing and Quality Assurance is responsible for leading and overseeing the organization's Financial Crimes Independent Testing and Quality Assurance Program across BSA/AML, Sanctions, Fraud, and related Financial Crimes Compliance activities.

This role provides strategic leadership and independent oversight of the design, implementation, execution, and effectiveness of Financial Crimes processes and controls across the First Line of Defense (1LoD) and Second Line of Defense (2LoD). The VP is responsible for establishing and maintaining a comprehensive, risk-based Independent Testing and Quality Assurance framework designed to evaluate whether Financial Crimes activities are operating effectively, consistently, and in accordance with regulatory expectations, internal policies, procedures, and established risk management standards.

The VP will oversee the Financial Crimes QA Manager and QA team and will be accountable for the overall strategy, governance, methodology, planning, execution, reporting, and continuous improvement of the Independent Testing and QA Program.

The role will provide independent and credible challenge to Financial Crimes leadership and stakeholders by identifying control weaknesses, execution deficiencies, governance gaps, systemic issues, and emerging risks. The VP will work collaboratively across business lines, Financial Crimes Compliance, Risk Management, Technology, Model Risk Management, and Internal Audit to strengthen the organization's Financial Crimes control environment and overall risk management framework.

What You Will Do:

Independent Testing and Quality Assurance Program Leadership

• Own and lead the enterprise Financial Crimes Independent Testing and Quality Assurance Program.

• Establish the strategic vision, governance framework, operating model, and standards for independent testing and QA activities.

• Develop and maintain a comprehensive, risk-based testing universe covering Financial Crimes processes, risks, controls, and activities across 1LoD and 2LoD.

• Establish a risk-based annual and ongoing testing plan based on factors including:

• Inherent Financial Crimes risk, regulatory exposure, control complexity and criticality, customer, product, service, and geographic risk, transaction volumes, prior findings and control performance, regulatory and audit findings, emerging risks and typologies, and material changes to systems, processes, products, or organizational structures

• Ensure appropriate testing coverage across BSA/AML, Sanctions, Fraud, Customer Due Diligence, Transaction Monitoring, Customer Risk Rating, Suspicious Activity Reporting, and other Financial Crimes activities, as applicable.

• Ensure testing and QA activities remain appropriately independent from the processes and controls being reviewed.

First & Second Line of Defense Independent Testing and Quality Assurance

Oversee the independent testing of key 1LoD and 2LoD Financial Crimes processes and controls, including, as applicable:

• Risk Assessment

• Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

• Customer onboarding and Know Your Customer (KYC) activities

• Transaction Monitoring alert investigation and disposition

• Suspicious Activity Report (SAR) escalation and decision-making

• Sanctions screening, investigation, and disposition

• Fraud detection and investigation activities

• Customer Risk Rating execution

• High-risk customer management

• Periodic and event-driven customer reviews

• Financial Crimes operational procedures and controls

• Financial Crimes Oversight and governance forum activities, including escalations, issue management, change management, metrics and reporting

• Data quality and key Financial Crimes data processes

Testing should evaluate, as applicable:

• Control design and implementation, operating effectiveness, accuracy and completeness, quality, timeliness, sustainability, evidentiary support, and appropriateness of disposition and escalation decisions

The role should maintain the distinction between assessing 1LoD execution deficiencies and evaluating 2LoD oversight or governance deficiencies, consistent with the underlying QA framework.

Testing Framework and Methodology Development

• Establish and maintain standardized methodologies for Financial Crimes Independent Testing and Quality Assurance.

• Own testing standards, procedures, and minimum documentation requirements.

• Approve and/or oversee the development of:

• Risk assessments, test plans, test scripts, sampling methodologies, workpaper standards, QA scoring frameworks, defect taxonomies, issue severity methodologies, and reporting standards

• Establish risk-based sampling methodologies based on population size, risk, complexity, materiality, prior performance, and control effectiveness.

• Define clear standards for evaluating:

• Control design effectiveness and implementation, operatin