Director, Financial Crimes Compliance

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 1,800 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 Role:

As the Director, Financial Crimes Compliance you will play a key role in providing guidance in supporting Upstart Bank’s FCC program. If you are excited by designing scalable compliance solutions, and building trusted relationships across a fast-moving fintech, this role is for you.

How you’ll make an impact

Develop, implement, and maintain Upstart’s Enterprise-Wide BSA/AML/OFAC Compliance Program,

ensuring it remains aligned with regulatory requirements, evolving financial crime risks, and the company’s risk appetite.

Lead enterprise-wide BSA/AML and sanctions risk assessments,

identify emerging risks, establish risk-based controls, monitoring frameworks, and governance processes to mitigate financial crime exposure.

Present regular reporting to the Board of Directors,

executive leadership, and risk committees, including risk assessment results, program effectiveness metrics, key risk indicators (KRIs), regulatory developments, and remediation progress.

Manage a comprehensive Customer Identification Program (CIP),

Know Your Customer (KYC), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) framework, including oversight of customer risk rating methodologies and ongoing monitoring activities.

Oversee review & management of high-risk customer relationships including onboarding decisions,

periodic reviews, escalation processes, and recommendations regarding customer exits or relationship terminations.

Provide senior-level oversight & strategic guidance for complex investigations involving unusual activity,

suspicious activity reporting (SAR), and regulatory reporting obligations.

Serve as primary point of contact for regulatory examinations,

independent audits, and compliance reviews related to BSA/AML & sanctions compliance ensuring timely & effective remediation of identified issues.

Partner with Product,

Engineering, Operations, Legal & Risk teams to design scalable financial crime controls for new products including consumer deposit & lending products.

Qualifications & Experience

10+ years experience leading BSA/AML compliance programs within bank/credit union/fintech or other regulated financial institution.
Deep knowledge of Bank Secrecy Act (BSA), USA PATRIOT Act OFAC sanctions requirements FinCEN guidance Know Your Customer (KYC) Customer Identification Program (CIP) Customer Due Diligence (CDD) Enhanced Due Diligence (EDD) Suspicious Activity Reporting (SAR) requirements.
Experience completing BSA/AML/OFAC risk assessments & using results to build/enhance/manage BSA/AML compliance programs supporting consumer deposit products & lending products.
Experience overseeing high-risk customer programs customer risk rating methodologies enhanced due diligence reviews customer relationship termination decisions.
Demonstrated experience leading regulatory examinations independent audits remediation efforts related to BSA/AML & sanctions compliance.
Experience presenting financial crime compliance matters risk assessments program metrics senior executives risk committees Boards of Directors.
Knowledge consumer banking regulations applicable deposit lending products.
CAMS Certified Anti-Money Laundering Specialist CAFP Certified AML Fraud Professional CRCM or comparable compliance certification.
Experience serving as BSA Officer Deputy BSA Officer or senior financial crimes compliance leader within highly regulated financial institution.
Experience building scaling AML transaction monitoring sanctions screening customer risk scoring implementing case management programs.
Experience using AI powered solutions scale automate BSA program work
Knowledge digital banking fintech embedded finance marketplace lending business models.
Experience implementing technology-enabled compliance solutions automated controls risk monitoring frameworks.
Experience working directly with federal state banking regulators including OCC FDIC Federal Reserve CFPB FinCEN state banking agencies.
Familiarity fraud risk management frameworks intersection fraud AML compliance programs.

Compensation & Benefits

At Upstart your base pay is one part your total compensation package. Anticipated base salary expected within below range Your actual base pay depends on geographic location–with our “digital first” philosophy Upstart uses compensation regions vary depending on location Individual pay determined by job-related skills experience relevant education training Your recruiter can share more about specific salary range preferred location during hiring process. Financial wellness resources including access financial planning tools financial concierge service US Only Annual productivity allowance invest relevant tools resources need do best work no matter where work from