Compliance Manager, BSA/AML Program

About this role

About Upstart

At Upstart, we’re united by a mission that matters: to radically reduce the cost and complexity of borrowing for all Americans. Every day, we bring creativity, experimentation, and advanced AI to reshape access to credit, helping millions move forward financially with clarity and confidence.

As the leading AI lending marketplace, we partner with banks and credit unions to expand access to affordable credit through technology that’s both radically intelligent and deeply human. Our platform runs over one million predictions per borrower using more than 3,000 signals, powering smarter, fairer decisions for millions of customers. But the numbers only hint at the impact. Every idea, every voice, and every contribution moves us closer to a world where credit never stands between people and their financial progress.

We’re proudly digital-first, giving most Upstarters the flexibility to do their best work from wherever they thrive, alongside teammates across 80+ cities in the US and Canada. Digital-first doesn’t mean distant. We’re intentional about in-person connection through team onsites, planning sessions, and moments that spark creativity and trust. And whether you choose to work primarily from home or collaborate in-person from one of our offices in Columbus, Austin, the Bay Area, or New York City (opening Summer 2026), you’ll have the support to work in the way that works best for you.

If you’re energized by tackling meaningful problems, excited to innovate with purpose, and motivated by work that truly matters, we’d love to hear from you.

The Team:

Upstart's Bank Secrecy Act/Anti-Money Laundering Compliance team is responsible for designing, implementing, and overseeing the company's enterprise BSA/AML Program, Customer Identification Program (CIP), Customer Due Diligence (CDD), sanctions, and suspicious activity compliance programs. We partner closely with Product, Engineering, Operations, Legal, Fraud, and Enterprise Risk to ensure our products and services are built on a strong foundation of regulatory compliance and effective risk management. We build scalable, risk-based programs that evolve alongside our products and regulatory expectations.

As the Compliance Manager, BSA/AML Program at Upstart, you will serve as a BSA/AML subject matter expert for Upstart Bank’s secured and unsecured lending products and support the development of new deposit products. Using a risk-based approach, you will evaluate changes to identify risks, develop controls, and measure ongoing performance of changes to ensure products and services are implemented within a strong compliance framework.

How you’ll make an impact

• Lead the design, execution, and continuous improvement of BSA/AML, Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), transaction monitoring, and sanctions screening processes for secured lending, unsecured lending, and deposit account products.

• Serve as a BSA/AML Compliance advisor for deposit product initiatives, partnering with Product, Legal, Operations, Engineering, and Enterprise Risk throughout product development and implementation.

• Develop and manage BSA/AML compliance initiatives, including new deposit product launches, regulatory enhancements, and control improvements.

• Administer ongoing customer due diligence and enhanced due diligence programs for deposit accounts in alignment with Upstart's Customer Identification Program (CIP), Red Flags Program, and BSA/AML compliance procedures.

• Evaluate relevant risks and typologies to develop appropriate transaction monitoring rules and efficient investigations processes

• Monitor evolving regulatory requirements, including FinCEN guidance, OFAC sanctions, and FFIEC BSA/AML examination expectations, to translate regulatory changes into scalable business processes and controls.

• Develop key risk indicators (KRIs), key performance indicators (KPIs), and management reporting that provide actionable insights into BSA/AML program effectiveness.

• Translate regulatory requirements and risk trends into clear recommendations for business stakeholders and senior leadership.

• Drive remediation efforts for examination, audit, monitoring, and testing findings while strengthening the overall BSA/AML compliance control environment.

Minimum Qualifications

• Bachelor's degree or equivalent practical experience.

• 7+ years of experience in BSA/AML compliance, financial crimes compliance, or a related Risk or Compliance role within a bank or other regulated financial institution.

• Experience implementing and managing customer onboarding processes including identity verification, customer due diligence (CDD), enhanced due diligence (EDD), sanctions screening, and ongoing monitoring processes.

• Working knowledge of regulatory requirements, including the Bank Secrecy Act (BSA), USA PATRIOT Act, and Customer Due Diligence Rule, and BSA/AML risks associated with deposit products

• Experience developing and delivering AML risk assessments, KRIs/KPIs, and management reporting while leading cross-functional compliance initiatives.

• Strong organizational, analytical, communication skills.

• Ability to identify gaps in policies and procedures and drive resolution and closure

• Experience in audit and exam readiness, including evidence gathering, testing and monitoring, addressing findings, responding to requests.

Preferred Qualifications

• Certified Anti-Money Laundering Specialist (CAMS), Certified AML and Fraud Professional (CAFP), or equivalent certification.

• Experience supporting deposit products, including high-yield savings accounts, certificates of deposit, brokered deposits, or similar banking products.

• Familiarity with implementing BSA/AML tools for transaction monitoring, case management, and customer screening

• Experience working with examiners, auditors, and other third-parties.

• Knowledge of regulatory change management and implementing new BSA/AML requirements.

• Ability to in

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