Coordinate as directed by the Chief BSA Officer or designated Manager, the dissemination of regulatory compliance regulations, related laws and guidance to Key's LOBs to ensure corporate-wide compliance with regulatory requirements. Act as a compliance relationship trusted advisor, concentrating on developing close partnerships with others in Risk Management, LOBs, marketing, legal and other support and administrative groups to identify and mitigate compliance risk. Work with steering committees, working groups, task forces, other Compliance and governance teams, and LOB partners to identify and manage compliance risks with assigned regulatory topics. Act as corporate SME resource for complex AML laws and regulatory requirements, inclusive of, BSA, USA PATRIOT Act, and OFAC. Effectively partner and establish relationships with LOB contacts, senior level management, legal, marketing and others, regarding corporate-wide compliance issues. Perform tasks related to merger and acquisition activities, contract reviews, risk assessments, compliance risk mitigation strategies, new or existing system and/or operational implementation. Design, communicate & evaluate AML Compliance policies and procedures for financial institution laws & regulations. Interact with regulatory agencies and the Risk Review group to respond to examination information requests, address exam findings, and respond to requests for comment. Participate in the Risk and Control Self Assessment process. Provide sound judgment and decision-making with regard to CDD and EDD reviews to mitigate risk exposure. Manage regulatory issues for the corporation to ensure sustained resolution. Provide senior managers with reports and information for the purpose of day to day follow-up on open compliance issues, decision-making, tactical objectives, and strategic planning. Participate in new business initiatives and due diligence activities to ensure compliance risks are appropriately identified and mitigated.

The SIU/EDD Operations Head is responsible for all aspects of the daily operations and management of the SIU and EDD investigative team. The SIU/EDD Head will manage a team of Analysts who will assist the bank in ensuring that BSA/AML EDD procedures and processes are adhered to through providing advice to and assisting business management and staff in on-boarding new clients (in particular, those deemed higher risk) and in the periodic refresh of know your customer documentation. The SIU/EDD Head is the organization's main focal point to ensure team results, and will be responsible for establishing short and long-term goals, developing training, operational, and business plans at the execution or tactical level, and developing team members for ever-increasing positions of responsibility within the unit's SIU/EDD. The SIU/EDD Head is the subject matter expert in AML investigative efforts, regulatory requirements at the operational level, and internal processes designed to optimize investigative performance. The SIU /EDD Head serves as primary liaison with the AML Compliance Solutions Team to optimize analyst performance and risk mitigation. The SIU/EDD Head is responsible for building liaisons with law enforcement agencies, inter-governmental bodies and other business units to ensure appropriate lines of communication within the department.

• Serve as a subject matter expert in analysis and provide training and ongoing mentoring to analysts on investigative techniques, internal First Niagara Financial Group (FNFG) account systems, and Bank Secrecy Act money laundering laws. • Continuous coaching and mentoring of staff, and responsible for staff level employee engagement. Also responsible for providing career opportunities, growth plans and bench-strength within the team. • Coordinating the goals and activities of Analysts, and providing upward reporting, including sustainability modeling and productivity/quality reporting. • Ensuring that case creation, alert/case assignment and alert/case/SAR aging are within First Niagara’s guidelines, and industry best practices and regulatory requirements, and provide upward reporting to the FIU AML Ops Head and/or BSA Officer. • Assisting the FIU AML Ops Head in ensuring that the development of written process and procedures documents accurately reflecting policy, the FIU level operations, and the translation of broad corporate guidance in to effective leadership behaviors. • Working with the AML Compliance Team regarding User Acceptance Testing, workflow processes, rule implementations, alert generation and system outages. Additionally, recommends efficiencies, streamlines processes and prepares upwards reporting of such.• Responsible for adherence to defined quality standards/core competencies that are required for all Analysts, specifically:o Proper Analysis skills;o Proper Research skills;o Proper Writing skills;o Proper Disposition; ando Decision Making.

Mitigating the risk exposure to the bank and monitoring transactional account activity in adherence to USA Patriot Act.

Responsible for assisting the AML/BSA Director on internal policies, procedures and controls to keep the bank in compliance with Federal Banking Regulations including but not limited to the Bank Secrecy Act, USA PATRIOT Act and OFAC. Evaluate and analyze AML Risk monitoring and controls to keep the Bank proactive with federal anti-money laundering regulatory changes, USA Patriot Act and industry standards, including but not limited to: enhancement of monitoring reports and establishing criteria for reporting purposes in order to implement appropriate risk controls.Oversee identification and monitoring of customers who meet the high risk criteria or who are politically exposed persons.Review new accounts that meet established high risk criteria to ensure that the Bank understands the business structure, beneficial owners, and associated risk level of the customer. Oversee the daily account monitoring of the PEP software.Assist AML/BSA Director in keeping the bank proactive with federal anti-money laundering regulatory changes, USA PATRIOT Act and industry standards, including but not limited to: KYC/EDD, training, criteria for reporting purposes.Assist in the AML training and implementation of new procedures to branch employees.Coordinate and direct the activities of the Financial Intelligence Unit Analysts and the AML Research Analysts.Make necessary decisions for personnel regarding employment, performance appraisals, salary recommendations, promotions and terminations.Provide input and suggestions on the AML monitoring software for system adjustments and updates and to ensure all are performed as expected through testing and implementation.

Development, coordination and oversight of the BSA/CTR unit and related initiatives that conform to regulatory guidelines and related operational policies.