Senior Compliance & Underwriting Analyst
Citcon USA LLC | Remote (United States) | Full-Time |
Reports to: Chief Risk & Compliance Officer
About Citcon
Citcon is a global payments company enabling cross-border digital wallet acceptance — WeChat Pay, Alipay, UnionPay
and other alternative payment methods — for merchants across the United States, Canada, Australia and Hong Kong.
The Role
We are hiring a Senior Compliance & Underwriting Analyst to own merchant underwriting end to end and to strengthen the policy and control environment around it. This is a hands-on individual reporting directly to the Chief Risk & Compliance Officer.
We use AI-assisted tooling across the underwriting workflow. We are looking for someone who uses those tools well and who knows when they are wrong. The ability to challenge a machine-generated conclusion and document why is a requirement of this role, not a bonus.
What You Will Do
Merchant Underwriting & Merchant Risk
• Own new merchant underwriting end to end: KYB and entity verification, beneficial ownership and control structure, sanctions and adverse media, financial review, website and acceptable use policy assessment, and processing history analysis.
• Assess merchant risk against prohibited and restricted business policy; assign risk ratings, set conditions and limits, and write the approve, decline or conditional-approval rationale so it stands on its own in a file review.
•Underwrite higher-risk and cross-border merchant profiles, including marketplaces, aggregation models and merchants of record.
• Conduct periodic merchant reviews and risk re-ratings; identify material change in business model, ownership, volume or chargeback profile and escalate accordingly.
• Manage offboarding and termination workstreams, including settlement holds, reserve decisions, notice documentation and the associated evidence file.
• Partner with Sales, Operations and Product on onboarding and merchant questions while maintaining second-line independence in the decision itself.
• Identify patterns across the portfolio that indicate emerging risk, and propose changes to underwriting criteria based on them.
Policy, Internal Controls & Audit Support
• Draft and maintain underwriting policy, prohibited and restricted business policy, acceptable use policy, and the supporting procedures and desk-level work instructions.
• Run the annual policy review cycle: version control, change logs, cross-references, and routing for management and committee approval.
• Document the internal control environment supporting underwriting and AML — control objectives, owners, frequency, and the evidence each control produces — and keep it testable by a third party.
• Identify control gaps and design practical compensating controls; distinguish a control that exists on paper from one that operates.
• Serve as a working-level point of contact for external auditors, third-party independent AML reviewers, state examiners, and bank and sponsor partner due diligence teams: assemble document request responses, prepare sample populations, and walk reviewers through process.
• Track audit, examination and review findings through remediation to documented closure.
BSA/AML & Money Transmitter Licensing Support
• Support transaction monitoring alert review, sanctions and negative news disposition, and enhanced due diligence on higher-risk counterparties.
• Contribute to Suspicious Activity Report drafting and the annual AML risk assessment.
• Support preparation of the NMLS Money Services Businesses Call Report and annual state license renewals,including data reconciliation with Finance.
• Support the state examination process.
What You Need
Required
• 5+ years in merchant underwriting, merchant risk or business-customer due diligence at a payment service provider, payment facilitator, acquirer, money services business or fintech.
• Demonstrated ownership of underwriting decisions, not just file preparation — you have made approve and decline calls and defended them.
• Experience drafting and maintaining policy and procedure documents that survived external review.
• Working understanding of internal controls: what a control is, who owns it, what evidence it produces, and how it fails.
• Direct experience supporting external audits, independent third-party reviews, regulatory examinations or partner due diligence, including managing document requests and tracking findings to closure.
• Working experience using AI or machine-assisted tools in a risk, compliance or underwriting workflow, with the judgment to challenge their output. Be prepared to describe a specific instance where you overrode a system-generated or AI-generated recommendation, and why.
• Practical BSA/AML knowledge: the BSA, USA PATRIOT Act, FinCEN MSB rules and OFAC sanctions requirements as they apply to a money transmitter.
• Familiarity with money transmitter licensing obligations and state money transmission law.
• Clear, examination-grade written analysis.
• Ability to work core Pacific Time business hours.
Preferred
• CAMS certification, or CFCS, CFE or equivalent.
• Cross-border payments experience; familiarity with alternative payment methods or digital wallets.
• Hands-on experience with NMLS filings or MSB Call Report preparation.
• Exposure to Canadian requirements is a plus: FINTRAC registration and reporting, PCMLTFA.
• Experience with sanctions and adverse media platforms such as World-Check, LexisNexis, Dow Jones and other major vendors.
Location, Hours and Travel
Fully remote within the United States with occasional travel (less than 10%) to the headquarters.
