Senior Compliance & Underwriting Analyst

Posted 2 days ago

citconDenver (CO)

SENIORITY

Senior

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About the role

About Citcon Citcon is a global payments company enabling cross-border digital wallet acceptance — WeChat Pay, Alipay, Union Pay and other alternative payment methods — for merchants across the United States, Canada, Australia and Hong Kong.
The Role: We are hiring a Senior Compliance & Underwriting Analyst to own merchant underwriting end to end and to strengthen the policy and control environment around it. This is a hands-on individual reporting directly to the Chief Risk & Compliance Officer. We use AI-assisted tooling across the underwriting workflow. We are looking for someone who uses those tools well and who knows when they are wrong. The ability to challenge a machine generated conclusion and document why is a requirement of this role, not a bonus.
What You Will Do: Merchant Underwriting & Merchant Risk• Own new merchant underwriting end to end: KYB and entity verification, beneficial ownership and control structure, sanctions and adverse media, financial review, website and acceptable use policy assessment, and processing history analysis.• Assess merchant risk against prohibited and restricted business policy; assign risk ratings, set conditions and limits, and write the approve, decline or conditional-approval rationale so it stands on its own in a file review.• Underwrite higher-risk and cross-border merchant profiles, including marketplaces, aggregation models and merchants of record.• Conduct periodic merchant reviews and risk re-ratings; identify material change in business model, ownership, volume or chargeback profile and escalate accordingly.• Manage offboarding and termination workstreams, including settlement holds, reserve decisions, notice documentation and the associated evidence file.• Partner with Sales, Operations and Product on onboarding and merchant questions while maintaining second-line independence in the decision itself.• Identify patterns across the portfolio that indicate emerging risk, and propose changes to underwriting criteria based on them. Policy, Internal Controls & Audit Support• Draft and maintain underwriting policy, prohibited and restricted business policy, acceptable use policy, and the supporting procedures and desk-level work instructions.• Run the annual policy review cycle: version control, change logs, cross-references, and routing for management and committee approval.• Document the internal control environment supporting underwriting and AML — control objectives, owners, frequency, and the evidence each control produces — and keep it testable by a third party.• Identify control gaps and design practical compensating controls; distinguish a control that exists on paper from one that operates.• Serve as a working-level point of contact for external auditors, third-party independent AML reviewers, state examiners, and bank and sponsor partner due diligence teams: assemble document request responses, prepare sample populations, and walk reviewers through process.• Track audit, examination and review findings through remediation to documented closure. BSA/AML & Money Transmitter Licensing Support• Support transaction monitoring alert review, sanctions and negative news disposition, and enhanced due diligence on higher-risk counterparties.• Contribute to Suspicious Activity Report drafting and the annual AML risk assessment.• Support preparation of the NMLS Money Services Businesses Call Report and annual state license renewals, including data reconciliation with Finance.• Support the state examination process.
What You Need: Required• 5+ years in merchant underwriting, merchant risk or business-customer due diligence at a payment service provider, payment facilitator, acquirer, money services business or fintech.• Demonstrated ownership of underwriting decisions, not just file preparation — you have made approve and decline calls and defended them.• Experience drafting and maintaining policy and procedure documents that survived external review.• Working understanding of internal controls: what a control is, who owns it, what evidence it produces, and how it fails.• Direct experience supporting external audits, independent third-party reviews, regulatory examinations or partner due diligence, including managing document requests and tracking findings to closure.• Working experience using AI or machine-assisted tools in a risk, compliance or underwriting workflow, with the judgment to challenge their output. Be prepared to describe a specific instance where you overrode a system-generated or AI-generated recommendation, and why.• Practical BSA/AML knowledge: the BSA, USA PATRIOT Act, FinCEN MSB rules and OFAC sanctions requirements as they apply to a money transmitter.• Familiarity with money transmitter licensing obligations and state money transmission law.• Clear, examination-grade written analysis.• Ability to work core Pacific Time business hours. Preferred• CAMS certification, or CFCS, CFE or equivalent.• Cross-border payments experience; familiarity with alternative payment methods or digital wallets.• Hands-on experience with NMLS filings or MSB Call Report preparation.• Exposure to Canadian requirements is a plus: FINTRAC registration and reporting, PCMLTFA.• Experience with sanctions and adverse media platforms such as World-Check, Lexis Nexis, Dow Jones and other major vendors. Location, Hours and Travel Fully remote within the United States with occasional travel (less than 10%) to the headquarters.

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