FRAML Manager, Embedded Finance

Job Summary

The FRAML Manager, Embedded Finance is responsible for overseeing the day-to-day fraud, BSA/AML, OFAC, and suspicious activity monitoring responsibilities associated with the Bank’s Embedded Finance and Banking-as-a-Service relationships. This role supports the Bank’s integrated Fraud and AML risk management framework by overseeing transaction monitoring, alert reviews, investigations, partner activity, escalations, reporting, quality control, and program documentation related to embedded finance activity.

Reporting directly to the Chief BSA Officer, the FRAML Manager serves as a working manager who actively participates in alert reviews, case management, fraud and AML investigations, quality control, suspicious activity identification, partner monitoring, and program enhancement. The position works closely with Embedded Finance, Operations, Compliance, Information Security, Treasury Management, Deposit Operations, and other applicable business units to identify fraud, money laundering, sanctions, and operational risks within embedded finance relationships.

The FRAML Manager is responsible for ensuring embedded finance activity is monitored in accordance with bank policies, regulatory requirements, established procedures, partner expectations, and risk-based oversight standards. This includes ensuring appropriate coordination between fraud and AML processes where risks overlap, while maintaining clear documentation, timely escalation, and examiner-defensible support for decisions.

Responsibilities and Duties

• Manage FRAML staff supporting Embedded Finance, including work assignments, productivity, coaching, training, professional development, performance management, and oversight of recurring and ad hoc responsibilities.
• Serve as a working manager by conducting and overseeing transaction monitoring, fraud and AML alert reviews, investigations, case management, quality control activities, and escalations related to Embedded Finance relationships.
• Oversee fraud, AML, OFAC, and suspicious activity monitoring associated with Embedded Finance programs, including account activity, transaction patterns, customer behavior, partner activity, fraud indicators, sanctions concerns, and emerging typologies.
• Review alerts, investigations, and cases to identify suspicious activity, fraud risks, money laundering concerns, unusual customer activity, and matters requiring enhanced monitoring, account restrictions, customer outreach, SAR consideration, or other risk mitigation actions.
• Coordinate with the Chief BSA Officer on SAR decisioning, SAR narratives, supporting documentation, case conclusions, and escalation of significant fraud, AML, sanctions, or suspicious activity concerns.
• Maintain quality control standards for alert reviews, investigations, case documentation, escalations, and closure rationale to ensure consistency with departmental procedures and regulatory expectations.
• Maintain key risk indicators, management reporting, alert and case metrics, fraud loss and recovery statistics, escalation trends, typology reporting, and other program performance data to support effective oversight.
• Collaborate with Embedded Finance, Operations, Deposit Operations, Treasury Management, Compliance, Information Security, and other business units to coordinate investigations, partner escalations, customer claims, account restrictions, fraud mitigation efforts, and operational processes.
• Assist in the onboarding, ongoing monitoring, and periodic review of Embedded Finance relationships by evaluating fraud, AML, OFAC, customer due diligence, transaction monitoring, operational controls, and overall risk management considerations.
• Support ongoing third-party and partner oversight through review of activity trends, exception reporting, audit and compliance results, monitoring outputs, due diligence documentation, and escalation items.
• Evaluate and enhance fraud and AML monitoring systems, rules, thresholds, reporting, and control processes, including participation in system implementations, testing, validations, data integrity reviews, and rule tuning activities.
• Ensure monitoring systems, automated jobs, reporting feeds, and transaction monitoring outputs are functioning as expected, coordinating with IT, vendors, and business partners to address identified issues.
• Oversee and support compliance with applicable 314(a), 314(b), OFAC, CTR, SAR, high-risk customer, and enhanced due diligence requirements as they relate to Embedded Finance activities.
• Develop, maintain, and update FRAML procedures, investigation methodologies, quality assurance standards, partner oversight documentation, and other program materials supporting Embedded Finance activities.
• Assist with audits, examinations, regulatory reviews, risk assessments, training initiatives, board reporting, and program enhancement efforts related to Embedded Finance FRAML activities.
• Stay informed of fraud, BSA/AML, OFAC, sanctions, fintech, Banking-as-a-Service, payment, and regulatory developments impacting the Bank's FRAML program.
• Provide back-up support to the Chief BSA Officer and other FRAML leadership functions as needed.
• Perform all other duties and responsibilities assigned by the Chief BSA Officer.

Qualifications and Skills

• Bachelor's degree preferred, or an equivalent combination of education and experience.
• Minimum five (5) years of experience in BSA/AML, fraud investigations, fraud risk management, compliance, banking operations, Embedded Finance, fintech, payments, or related financial services disciplines.
• Minimum three (3) years of supervisory, team lead, or management experience preferred.
• Strong knowledge of BSA/AML, OFAC, suspicious activity reporting, customer due diligence, enhanced due diligence, fraud risk management, Regulation E, and applicable regulatory requirements.
• Strong understanding of FRAML principles, including the integration of fraud and AML risk identification, transaction monitoring, investigations, escalation, reporting, and control processes.
• Knowledge of Embedded Finance, Banking-as-a-Service (BaaS), fintech partnerships, payment ecosystems, digital account activity, transaction monitoring, and third-party risk oversight preferred.
• Strong knowledge of fraud typologies and emerging threats, including account takeover, identity theft, elder financial exploitation, ACH, wire, debit card, check, deposit, and payment fraud.
• Ability to identify fraud indicators, AML red flags, suspicious transaction patterns, sanctions concerns, and elevated customer or partner risk.
• Strong analytical, investigative, organizational, critical thinking, and problem-solving skills, with the ability to implement practical, risk-based solutions and exercise sound judgment.
• Demonstrated ability to lead employees, manage workloads, prioritize assignments, monitor productivity, and develop team members.
• Strong interpersonal and communication skills, including the ability to build effective relationships across business lines and present risks, trends, findings, and recommendations to management and executive leadership.
• Ability to work independently, manage multiple priorities, and maintain clear, examiner-defensible documentation.
• Proficient in Microsoft Office applications, including Excel, Word, Outlook, and PowerPoint.
• Experience with Sardine, Socure, Verafin, Unit21, fraud monitoring systems, case management platforms, OFAC screening solutions, partner monitoring tools, or similar investigative software preferred.
• CAMS, CFCS, CAFP, CRCM, or other relevant industry certification preferred.