BSA Officer

About PayPal

PayPal has been revolutionizing commerce globally for more than 25 years. Creating innovative experiences that make moving money, selling, and shopping simple, personalized, and secure, PayPal empowers consumers and businesses in approximately 200 markets to join and thrive in the global economy.

We operate a global, two-sided network at scale that connects hundreds of millions of merchants and consumers. We help merchants and consumers connect, transact, and complete payments, whether they are online or in person. PayPal is more than a connection to third-party payment networks. We provide proprietary payment solutions accepted by merchants that enable the completion of payments on our platform on behalf of our customers.

We offer our customers the flexibility to use their accounts to purchase and receive payments for goods and services, as well as the ability to transfer and withdraw funds. We enable consumers to exchange funds more safely with merchants using a variety of funding sources, which may include a bank account, a PayPal or Venmo account balance, PayPal and Venmo branded credit products, a credit card, a debit card, certain cryptocurrencies, or other stored value products such as gift cards, and eligible credit card rewards. Our PayPal, Venmo, and Xoom products also make it safer and simpler for friends and family to transfer funds to each other. We offer merchants an end-to-end payments solution that provides authorization and settlement capabilities, as well as instant access to funds and payouts. We also help merchants connect with their customers, process exchanges and returns, and manage risk. We enable consumers to engage in cross-border shopping and merchants to extend their global reach while reducing the complexity and friction involved in enabling cross-border trade.

Our beliefs are the foundation for how we conduct business every day. We live each day guided by our core values of Inclusion, Innovation, Collaboration, and Wellness. Together, our values ensure that we work together as one global team with our customers at the center of everything we do – and they push us to ensure we take care of ourselves, each other, and our communities.

Job Description Summary

The Bank Secrecy Act (BSA) Officer will serve as PayPal Bank’s (PPB) program owner and accountable executive for establishing, implementing, and sustaining the bank’s AML/CFT/OFAC compliance framework suitable for a de novo FDIC-insured ILC. This role will build the program from the ground up to support charter-readiness, ensure effective identification and mitigation of financial crime risks (including AML/CFT, USA PATRIOT Act, OFAC, and CIP/CDD), and deliver strong governance and reporting to PPB senior management and the Board. The Officer will also lead day-to-day program execution and ensure the Bank is continuously exam-ready through robust monitoring, high-quality regulatory reporting, and strong issue remediation. In this role, the BSA Officer will report to the ILC’s Chief Risk Officer (“CRO”).

Essential Responsibilities

• Establish overall business and technical strategies for entity management that significantly impact PayPal operations.
• Advise on complex legal and regulatory compliance issues related to corporate structures.
• Influence executive-level decision-making through strategic insights and recommendations.
• Ensure the efficient operation of the organization’s diverse entities by maintaining compliance with laws and regulations.
• Lead initiatives that promote effective governance and risk management across the organization.

Key Responsibilities

• Own and administer the Bank’s AML/CFT/OFAC program, including program design, customer risk profiles, risk assessments, internal controls, customer identification, due diligence, and trainings.
• Lead enterprise AML/CFT/OFAC risk assessment activities and drive risk-based controls to mitigate identified risks.
• Oversee financial crime monitoring and investigations governance, including alert management standards, case documentation, and escalation of emerging issues to senior management.
• Ensure timely, accurate regulatory reporting and program operations (e.g., SAR/CTR governance, exemptions, and supporting documentation standards).
• Establish and maintain a comprehensive training program for employees and Board members on AML/CFT/OFAC obligations.
• Manage issue identification, tracking, and remediation tied to internal QA, independent testing/audit, and regulatory exams, with clear reporting to governance forums.
• Ensure effective oversight of any outsourced/affiliate-provided AML operations and technology, including performance metrics, quality controls, and SLA adherence (where applicable).
• Engage with internal audit and external regulators where required to represent the program.

De Novo Charter Formation & ILC Buildout

• Stand up PPB’s foundational AML/CFT/OFAC program artifacts for FDIC and state charter review: program charter, policies, procedures, governance cadence, and control inventory.
• Design the initial AML/CFT risk assessment approach aligned to the proposed business model, products, delivery channels, and customer types, and ensure controls scale with growth.
• Define the Bank’s core compliance program components (CIP, CDD/EDD, OFAC screening, transaction monitoring, investigations/SAR governance, recordkeeping) and ensure build-out aligns to regulatory expectations for a new bank.
• Develop first-line and second-line operating model, including staffing plan, role delineation, training plan, and vendor/technology implementation roadmap.
• Establish initial management and Board reporting packages (metrics, KRIs, issues, model/threshold changes, training completion, audit/exam readiness, and risk appetite thresholds / triggers).

Ongoing Program Leadership (Post Opening)

• Operate and continuously enhance the AML/CFT/OFAC program using a risk-based approach, including periodic updates to risk assessments, policies, procedures, and monitoring rules.
• Oversee ongoing operational processes (e.g., SAR/CTR program governance, exemptions, investigative standards, QA/quality control) and ensure consistent documentation and defensibility.
• Maintain and mature the training program for employees and the Board at least annually, and as risk, products, and regulations evolve.
• Lead continuous improvement through monitoring, QA, and independent testing readiness; ensure timely remediation of findings and sustained closure.
• Own program change management, including new products, new customer segments, technology changes, and material threshold/rule adjustments with governance approvals as required.

Regulator Engagement & Exams

• Serve as PPB’s primary point of contact for AML/CFT/OFAC matters with the FDIC and other relevant supervisors; coordinate responses, meetings, and submissions.
• Lead examination preparedness and execution: pre-exam self-assessments, evidence production, interview readiness, and on-site/virtual exam management.
• Coordinate independent testing/audit activities and ensure audit/exam findings are tracked, escalated appropriately, and remediated with effective corrective action.
• Provide clear governance updates to PPB management and Board committees on program effectiveness, key risks, and remediation status.

Culture, Training & Change Leadership

• Drive a strong “tone from the top” culture focused on bank employees and PayPal Inc. stakeholder engagement related to their responsibility of detecting and appropriately reporting financial crimes.
• Support development of the bank’s risk culture by ensuring timely and relevant AML/CFT/OFAC trainings are delivered and completed.

Governance & Reporting Lines

• Primary reporting: ILC Chief Risk Officer
• Governance reporting: Risk and Compliance Committee and Board
• Partnerships: All PPB executive leaders and PayPal Inc. stakeholders where oversight is required

Minimum Qualifications

• 10+ years relevant experience and a Bachelor’s degree OR Any equivalent combination of education and experience.

Required Qualifications

• Education: Bachelor’s degree in business, finance, economics, accounting, or a related discipline (or equivalent combination of education and experience).
• Experience (Director-level): 10+ years in BSA/AML/ CFT and financial crimes compliance within a bank or regulated financial institution, including demonstrated program leadership and governance experience.
• Demonstrated ownership of core AML/CFT/OFAC components (risk assessments, training, monitoring/controls, reporting governance, issue remediation).
• Strong ability to build and operationalize policies/procedures and lead cross-functional implementation across Compliance, Operations, Product, Technology, and Risk.
• Demonstrated ability to develop and deliver Board/Executive reporting and to drive remediation of audit/exam findings.

Preferred Qualifications

• CAMS (ACAMS) or equivalent AML Fraud / Financial Crimes certification.
• Prior experience as a designated BSA Officer/AML Officer for a bank or ILC (or as a deputy with clear accountability for program execution).
• Experience building or transforming AML programs in fast-growth, digital-first, or partner/embedded-finance environments (including vendor/tool selection and operating model design).
• Hands-on experience developing and delivering institution-wide AML/CFT/OFAC training programs, including Board training.
• Deep familiarity with SAR/CTR governance and documentation expectations, including CTR exemptions and investigative file quality standards.

Our Ways of Working:

For most employees, PayPal's balanced hybrid work model offers 3 days in the office for effective in-person collaboration and 2 days at your choice of either the PayPal office or your home workspace, ensuring that you equally have the benefits and conveniences of both locations. Travel of ~ 15% may be required based on business needs for regulatory agency visits, Board meetings, and other key partner / vendor meetings.

The base pay for this role will depend on where you work and the relevant experience and expertise you bring. The expected range of pay for this role by location is:

• Primary Location : Pay Range: Utah - (Virtual) : ($152,500.00 - $226,600.00 Annually)
• Additional Location(s) : Pay Range: San Jose, California : ($176,500.00 - $262,350.00 Annually)

Additional compensation for this role may include an annual performance bonus, equity, or other incentive compensation, as applicable.

PayPal does not charge candidates any fees for courses, applications, resume reviews, interviews, background checks, or onboarding. Any such request is a red flag and likely part of a scam. To learn more about how to identify and avoid recruitment fraud please visit https://careers.pypl.com/contact-us.

For the majority of employees, PayPal's balanced hybrid work model offers 3 days in the office for effective in-person collaboration and 2 days at your choice of either the PayPal office or your home workspace, ensuring that you equally have the benefits and conveniences of both locations.

Our Benefits:

At PayPal, we’re committed to building an equitable and inclusive global economy. And we can’t do this without our most important asset-you. That’s why we offer benefits to help you thrive in every stage of life. We champion your financial, physical, and mental health by offering valuable benefits and resources to help you care for the whole you.

We have great benefits including a flexible work environment, employee shares options, health and life insurance and more. To learn more about our benefits please visit https://www.paypalbenefits.com

Who We Are:

To learn more about our culture and community visit https://about.pypl.com/who-we-are/default.aspx

Commitment to Diversity and Inclusion

PayPal provides equal employment opportunity (EEO) to all persons regardless of age, color, national origin, citizenship status, physical or mental disability, race, religion, creed, gender, sex, pregnancy, sexual orientation, gender identity and/or expression, genetic information, marital status, status with regard to public assistance, veteran status, or any other characteristic protected by federal, state, or local law. In addition, PayPal will provide reasonable accommodations for qualified individuals with disabilities. If you are unable to submit an application because of incompatible assistive technology or a disability, please contact us at paypalglobaltalentacquisition@paypal.com.

Belonging at PayPal:

Our employees are central to advancing our mission, and we strive to create an environment where everyone can do their best work with a sense of purpose and belonging. Belonging at PayPal means creating a workplace with a sense of acceptance and security where all employees feel included and valued. We are proud to have a diverse workforce reflective of the merchants, consumers, and communities that we serve, and we continue to take tangible actions to cultivate inclusivity and belonging at PayPal.

Any general requests for consideration of your skills, please Join our Talent Community.

We know the confidence gap and imposter syndrome can get in the way of meeting spectacular candidates. Please don’t hesitate to apply.

REQ ID R0134408