The duties and responsibilities of the position are to be carried out in a manner that is consistent with the goals, values and operating principles of Banco do Brasil Americas, and in conformity with all laws and regulations governing the Bank. Every associate is to read and understand the policies and procedures of their department as well as those of the Bank to ensure smooth operations, satisfactory audits and examinations. Every associate is to conduct business relationships in a manner that will enhance the overall marketing effort of the Bank.

POSITION SUMMARY

The BSA High Risk Review Team Lead is responsible for leading and overseeing a team of Sr. Analysts who conduct the review of high-risk customer accounts. This role ensures high-risk customer accounts and their investigations are thorough, timely, well-documented, and consistent with applicable regulatory requirements, internal bank policies/procedures, and risk standards. The BSA High Risk Review Team Lead serves as a subject-matter expert (SME) of the high-risk customer account review and other complex investigations involving financial crimes, provides quality assurance and coaching, monitors team performance and deadlines, and partners with the BSA Officer and or Deputy BSA Officer, Risk, Legal, Fraud, and other stakeholders to identify and mitigate financial crime and sanctions risk. The BSA High Risk Review Team Lead ensures that all unusual and suspicious activities identified when completing the review of high-risk customer accounts are reported to FinCEN in a timely manner and comply with all applicable regulatory requirements.

ESSENTIAL DUTIES AND RESPONSIBILITIES

Lead, coach, and develop a team of High-Risk Review Sr. Analysts, including setting performance expectations and providing ongoing feedback. Oversee the timely and accurate completion of enhanced due diligence (EDD), high-risk customer reviews, transaction reviews, and escalated investigations. Review and approve complex or high-risk cases in accordance with established policies, procedures, and risk appetite. Ensure investigations are well-documented, supported by appropriate evidence, and demonstrate clear rationale for decisions and recommendations. Monitor team workloads, productivity, quality, aging, and service-level performance; identify and address operational gaps. Conduct quality assurance reviews and identify trends, recurring issues, and opportunities for process improvement. Serve as an escalation point for complex cases, unusual activity, adverse media, sanctions concerns, PEP exposure, fraud indicators, and other elevated-risk matters. Partner with Compliance, AML, Fraud, Sanctions, Legal, Risk, and Operations teams on complex investigations and risk decisions. Ensure team practices remain aligned with applicable regulatory requirements, internal policies, procedures, and risk standards. Develop and maintain reporting and management information related to high-risk review activity, case volumes, quality, productivity, and emerging risk trends. Identify opportunities to improve workflows, procedures, controls, and technology supporting the high-risk review process. Support audits, regulatory examinations, internal reviews, and other compliance-related initiatives. Participate in policy and procedure development, testing, implementation, and change-management activities. Maintain awareness of emerging financial crime, fraud, sanctions, and regulatory risks and communicate relevant developments to management and the team. Develops, maintains and revises policies and procedures with regards to BSA investigations. Provide proactive advice and guidance to the front and back-office personnel on

BSA AML OFAC

compliance matters. Direct deep-dive investigations into complex financial crimes and money laundering. Ensure accurate and timely filing of Suspicious Activity Reports (SARs) with FinCEN. Maintain compliance with federal banking laws and regulatory standards. Conduct performance reviews, training, and mentoring for team members. Partner with legal, risk, and law enforcement teams as needed\.

ADDITIONAL DUTIES AND RESPONSIBILITIES

Develop and update internal logs, reports, metrics as needed for BSA Management. Responsible for monitoring analysts' productions with regards to High-Risk Reviews and investigations, request for information, etc. Assists with OFAC related issues as appropriate. Make decisions based on Bank standards, policies and established procedures as well as compliance with the regulatory agencies. Decisions are also based on risk associated with the bank's activities, to promote a safe and sound banking environment. Communicates effectively with other stakeholders at the bank Escalate to Senior BSA Management in a timely manner financial crime, sanctions and or reputational risk Perform other related duties as required to accomplish the objectives of the position Assists BSA Management with interna audits, external examinations and in other BSA projects as needed.

EDUCATION AND/OR EXPERIENCE

Bachelor's degree (B.A) from qualified college or university preferred plus a minimum of 5 plus years of BSA AML compliance experience and preferably with at least two or three years of BSA management or BSA team-lead experience; ACAMS or CRCM certification preferred. Strong familiarity with AML/CFT Sanctions regulations and regulatory expectations, including KYC, CDD, EDD, sanctions, PEPs, adverse media and suspicious activity indicators.

OTHER SKILLS/QUALIFICATIONS

Bachelor's degree in business administration, criminal Justice, or a related field, or equivalent professional experience. 5+ years of experience in BSA/AML, financial crimes compliance, high-risk customers and complex investigations, fraud, sanctions, or a related field. 2+ years of management or team-lead experience overseeing investigators or compliance professionals. Strong Leadership skills Strong experience evaluating complex high risk customers or transactions risk and making wll supported escalation or disposition decisions. Clearly communicates findings, recommendations, and escalations to both operational and senior stakeholders Understands applicable regulatory requirements and translates them into effective operational practices Identifies opportunities to strengthen controls, improve efficiency, and reduce operational risk. Experience with complex financial crime investigations, cash intensive businesses, offshore-entities, political exposed persons, foreign bribery and corruption, foreign consulates/embassies, government related entities, correspondent banking, cryptocurrency, international/cross border transactions, or other higher-risk activity products and services. Strong knowledge of AML/CFT OFAC and FinCEN requirements, suspicious activity investigations, and financial crime risk management. Experience with transaction monitoring, case management, fraud detection, sanctions screening, or AML investigative platforms. Maintains high standard for investigation quality and documentation Experience responding to regulatory examinations or audits. Familiarity with current financial crime typologies, sanctions and regulatory expectations. Experience reviewing and/or approving SARs and complex investigations. Demonstrated ability to analyze complex financial activity and identify potentially suspicious patterns and behaviors. Strong understanding of investigative methodologies, documentation standards, and risk-based decision-making. Excellent written and verbal communication skills, including the ability to clearly articulate investigative findings to senior stakeholders. Strong organizational skills and ability to manage competing priorities in a deadline-driven environment. High degree of integrity, discretion, and sound professional judgment. Ability to effectively present information and respond to questions from employees and managers. Ability to work under pressure and meet Departmental deadlines in a timely manner. Excellent verbal and written communication skills Ability to communicate in both English and Portuguese highly desirable; Spanish useful. Ability to ensure confidentiality, security and safekeeping of bank and customer information In depth knowledge of all bank policies, procedures and compliance requirements Is consistently at work and on time; Ensures work responsibilities are covered when absent Takes responsibility for own actions; Commits to long hours of work when necessary to reach goals; ability to multitask; takes initiative; highly motivated Strong organizational skills with attention to detail; focused Displays behavioral and daily habits to accomplish Goals as assigned Displays original thinking and creativity; Generates suggestions for improving work, setting goals Treats others with respect and consideration regardless of their status or position. Demonstrates accuracy and thoroughness in all reports produced Must be accustomed to professional, business office environment in manner and dress Must demonstrate excellent human relations skills with bank associates Must be willing to participate and work effectively as a team member and eager to tackle new assignments Must be proficient in Microsoft Word and Excel Strong investigative judgment Strong Analytical and critical thinking skills Leadership and team development

BSA/AML OFAC

sanctions expertise Strong risk-based decision making Strong case and workload management skills Strong cross-functional collaboration Team player Experience preparing or reviewing SAR narratives. Familiarity with regulatory expectations and examination processes.