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Vice President & Chief Anti-Money Laundering Officer (CAMLO)

EQ Bank
2 days ago
Full-time
On-site
Toronto, Canada
Join a Challenger

Being a traditional bank just isn’t our thing, so we challenge ourselves to get creative in providing innovative banking solutions for Canadians.

How do we get there? With a talented team of inquisitive and agile challengers that break through the status quo. So, if you’re passionate about redefining the future of banking—while having fun—this could be your next big opportunity.

Our company continues to grow, and today we serve more than 800,000 customers across Canada through Equitable Bank, Canada's Challenger Bank™, and have been around for more than 50 years. Equitable Bank's wholly-owned subsidiary, Concentra Bank, supports credit unions across Canada that serve more than six million members. Together we have over $142 billion in combined assets under management and administration, with a clear mandate to drive change in Canadian banking to enrich people's lives. Our customers have named our EQ Bank digital platform (eqbank.ca) one of the top banks in Canada on the Forbes World's Best Banks list since 2021. 

The Work

The Chief Anti-Money Laundering Officer (CAMLO) is responsible for developing, implementing, and overseeing EQB’s enterprise-wide Anti-Money Laundering, Anti-Terrorist Financing, and Sanctions compliance program. The CAMLO’s purpose is to protect the bank and its subsidiaries from being used for illicit activities – such as money laundering, terrorist financing, or sanctions evasion – by ensuring full compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and associated regulations, as well as all guidance from the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).

In the context of EQB’s fintech-forward and digital banking operations, the CAMLO establishes controls that enable customer convenience and innovation while vigilantly guarding against financial crime. The ultimate mandate of this role is to maintain the integrity of the bank’s operations and the broader financial system by effectively managing ML/TF risk and satisfying regulatory expectations, thereby safeguarding EQB’s reputation and regulatory standing.

Enterprise AML/ATF Program Leadership:

  • Design and lead a comprehensive, risk-based AML/ATF/Sanctions compliance program covering all of EQB’s business lines and distribution channels.
  • Develop and update AML/ATF policies, procedures, and internal controls in alignment with legal requirements (PCMLTFA, Criminal Code, United Nations Act and Special Economic Measures Act for sanctions) and international best practices (e.g. FATF Recommendations).
  • Ensure these controls are tailored to the nature, size, and complexity of EQB’s operations, including its digital banking platform, and address the evolving methods of money laundering and terrorist financing.

Regulatory Compliance & Liaison (FINTRAC/OSFI):

  • Serve as the primary contact with FINTRAC for all AML/ATF reporting and examinations.
  • Oversee the timely and accurate submission of all required regulatory reports, such as Suspicious Transaction Reports (STRs), Electronic Funds Transfer Reports (EFTRs), Terrorist Property Reports, and any other filings mandated by the PCMLTFA and related regulations.
  • Coordinate with the relevant regulators on AML-related inquiries and ensure that expectations are met.
  • Lead the preparation for and response to regulatory audits or reviews of EQB’s AML program, and promptly implement any necessary corrective actions or recommendations.
  • Ensure compliance and adherence to all AML regulations and internal AML Regulatory Compliance Management is up to date

Risk Assessment & Controls:

  • Conduct and regularly refresh enterprise-wide assessments of inherent money laundering, terrorist financing, and sanctions evasion risk. Identify high-risk products, services, customer segments, and geographies in EQB’s profile.
  • Use these assessments to inform the design and calibration of controls – for example, setting parameters for transaction monitoring rules, defining due diligence standards for higher-risk customers (Enhanced Due Diligence), and updating sanctions screening protocols.
  • Ensure that any new product, service, or business initiative undergoes an AML risk review so that appropriate controls are in place before launch.
  • The CAMLO must continually “keep the program current” by adjusting controls in response to changes such as new regulatory typologies, emerging technologies (e.g., real-time payments), or shifts in the bank’s risk environment.

Detection, Monitoring, and Reporting Systems:

  • Oversee the operation of systems that detect transactions and customer behavior indicative of money laundering or terrorist financing, such as unusual transfers or links to sanctioned entities.
  • Ensure that automated transaction monitoring systems, sanctions screening tools, and customer risk rating models are effectively identifying potential issues and generating quality alerts.
  • Where manual reviews are required, ensure the team has the capacity and expertise to analyze those alerts.
  • Maintain clear investigative procedures for alert handling and decision-making on whether to file STRs.
  • Continuously refine the monitoring rules and thresholds to optimize detection (capturing true suspicious activity while minimizing “false positives”).
  • Additionally, confirm that all information gathering and reporting systems produce accurate data for management reports and regulatory filings, with consistency in criteria and definitions across the enterprise.

Investigations & Case Management:

  • Supervise investigations into suspicious activities or regulatory AML queries. This involves guiding a team of AML investigators or analysts in reviewing complex transactional patterns, analyzing customer profiles, and documenting findings.
  • Ensure that when suspicious activity is confirmed, appropriate internal actions are taken (such as account restrictions or exit decisions in partnership with business leadership and Legal), and that external reports (STRs or law enforcement referrals) are made swiftly.
  • Oversee a centralized case management process to track all investigations and their outcomes, maintaining an audit trail and ensuring issues are resolved or escalated in a timely manner.
  • Champion the responsible use of advanced analytics, machine learning, and AI‑enabled tools to enhance investigative effectiveness, decision quality, and throughput
  • Ensure AI and advanced analytics used in investigations are governed by strong model risk management, explainability, quality assurance, and human‑in‑the‑loop controls

Training & Awareness:

  • Implement ongoing AML/ATF and sanctions compliance training for all relevant employees, including front-line staff, operations, and senior management.
  • Tailor training programs to different audiences – for example, more in-depth training for employees in higher-risk roles (like those opening accounts or handling large transactions) – to ensure everyone understands how to identify and report unusual activities.
  • Additionally, train the Board of Directors and executive management annually on their oversight responsibilities and current AML/ATF risks.
  • Foster a culture of vigilance and compliance where employees are encouraged and obligated to raise any concerns about possible money laundering or fraud, knowing those concerns will be taken seriously.

Collaboration & Advisory Role:

  • Work closely with other departments and the first line of defense to embed AML controls into day-to-day processes.
  • Advise product and business teams on AML implications when designing new products or entering new partnerships (e.g., fintech collaborations, white-label services), ensuring that due diligence and monitoring considerations are built in.
  • Collaborate with the Fraud Management team and others in Risk to share information, as certain fraud schemes or cyber threats may have AML implications.
  • Provide expert guidance across the bank on client onboarding (KYC requirements), record-keeping, and how to handle regulatory requests or law enforcement inquiries.
  • Act as the internal subject matter expert on financial crime compliance, keeping senior leadership apprised of key developments (such as significant enforcement actions in the industry or new criminal typologies that could affect the bank).

Program Evaluation and Reporting:

  • Develop metrics and Key Performance Indicators (KPIs) to measure the effectiveness of the AML program (e.g., number of alerts, STR conversion rates, training completion rates, audit findings resolved).
  • Regularly report to senior management and the Board’s Governance/Nominating Committee on the state of the AML/ATF program.
  • On an annual basis, provide a formal written report (and presentation if required) to the Governance and Nominating Committee of the Board, offering your independent opinion on the adequacy of EQB’s AML/ATF/Sanctions program and whether it is functioning effectively to meet all legal requirements.

Continuous Improvement & Industry Engagement:

  • Stay abreast of evolving money laundering and terrorist financing techniques, as well as advancements in AML technology (e.g. RegTech solutions like AI-driven analytics, blockchain monitoring tools, etc.).
  • Proactively recommend and implement enhancements to EQB’s AML program – for example, system upgrades, new data sources for risk assessment, or process re-engineering to improve efficiency.
  • Represent EQB in relevant external forums, such as industry AML working groups or conferences, to benchmark the program against peers and share knowledge.
  • Continuously challenge the status quo of the AML program by asking how it can adapt to new threats or business changes, thereby ensuring the program remains robust and forward-looking.

Team Leadership and Collaboration:

  • Lead the AML Compliance Department and manage its personnel and resources.
  • Ensure the AML compliance function is adequately staffed and that team members possess the qualifications and training required to effectively manage the bank’s Money Laundering / Terrorist Financing risks.
  • Foster collaboration between AML Compliance and other departments (Risk Management, Legal, Internal Audit, Business Units, etc.) to address AML compliance issues through the appropriate channels.
  • Maintain independence, work closely with first-line business units and specialized compliance officers (e.g., Privacy Officer, Business Unit Compliance Officers).

Let's Talk About You!

  • Bachelor’s degree in Finance, Law, Criminology, Business or a related field.
  • An advanced degree or specialized training in financial crime is an asset. Professional certification is strongly preferred, such as Certified Anti-Money Laundering Specialist (CAMS) or similar credentials (e.g., CFCS – Certified Financial Crime Specialist).
  • Minimum 8–10 years of dedicated experience in anti-money laundering, anti-financial crime, or regulatory compliance within financial services. This should include several years in a leadership or designated CAMLO role where the individual has managed an institution’s AML/ATF program.
  • Experience working in a federally regulated financial institution (bank or trust company) in Canada is highly desirable, especially with direct exposure to FINTRAC examinations or OSFI compliance reviews.
  • In-depth knowledge of Canada’s AML laws and regulations, primarily the PCMLTFA and its regulations, and FINTRAC guidelines.
  • Must be well-versed in the obligations around customer identification (KYC), record-keeping, reporting thresholds, and the various report types (STRs, LCTRs/EFTRs, etc.) and sanctions lists.
  • Understanding of related regulatory expectations from OSFI (e.g., expectations under the Regulatory Compliance Management framework and OSFI’s AML assessment criteria) is important.
  • The individual should also be knowledgeable about global AML/CFT standards (FATF recommendations, Wolfsberg principles) and keep informed about international sanctions regimes (UN sanctions, US OFAC, etc.) that could impact the bank.
  • Strong analytical abilities with keen attention to detail. The role involves sifting through large volumes of data and complex transaction patterns, so the CAMLO must be adept at identifying red flags and making connections that are not immediately obvious.
  • Experience in conducting or overseeing financial investigations is critical – this includes skills in forensic analysis, understanding of typologies, and the ability to guide investigators on when and how to dig deeper.
  • Being comfortable with data analytics tools or even basic SQL or Excel analysis.
  • Ability to manage and develop a team of AML analysts, investigators, and compliance testers.
  • Should be able to set clear objectives and motivate the team, especially during peak workloads (such as a major project or regulatory exam).
  • Strong communication skills are essential – the CAMLO must communicate effectively with a variety of stakeholders: explaining complex financial crime risks to senior executives and the Board in a concise way, training front-line staff on their AML responsibilities in an accessible manner, and maintaining clear communications with regulators or law enforcement.
  • The ability to write high-quality policies, reports, and investigative narratives is also important.
  • High level of professional integrity and sound judgment. The CAMLO is entrusted with making sensitive decisions.
  • Must be able to make unbiased decisions, sometimes with incomplete information, in the best interest of the bank’s safety and compliance.
  • Should exemplify ethical conduct, as this role often serves as a moral compass in ensuring the bank does not wittingly or unwittingly facilitate illicit activity.
  • Must also ensure confidentiality of investigations and protect sensitive information, sharing details strictly on a need-to-know basis.
  • Flexibility and creativity in tackling new challenges.
  • The CAMLO should be someone who embraces continuous learning and can pivot strategies as needed.
What we offer [For full-time permanent roles]
 
💰 Competitive discretionary bonus 
✨ Market leading RRSP match program
🩺  Medical, dental, vision, life, and disability benefits
📝  Employee Share Purchase Plan
👶🏽 Maternity/Parental top-up while you care for your little one
🏝 Generous vacation policy and personal days 
🖥  Virtual events to connect with your fellow colleagues
🎓  Professional development and comprehensive Career Development program
💛  A fulfilling opportunity to join one of the top FinTechs and help create a new kind of banking experience

The incumbent will be working hybrid and in office time will be spent working from Equitable Bank’s additional office space located at 2200-25 Ontario Street, Toronto, ON.
  
Equitable Bank is deeply committed to inclusion. Our organization is stronger and our employees thrive when we honour and celebrate everyone’s diverse experiences and perspectives. In tandem with that commitment, we support and encourage our staff to grow not just in their career path, but personally as well. 

We commit to providing a barrier-free recruitment process and work environment for all applicants. Please let us know of any accommodations needed so that you can bring your best self to the application process and beyond. All candidates considered for hire must successfully pass a criminal background check and credit check to qualify for hire. While we appreciate your interest in applying, an Equitable recruiter will only contact leading candidates whose skills and qualifications closely match the requirements of the position.
 
We can’t wait to get to know you!