Title: Director, Sanctions Compliance Locations: Chicago, IL New York, NY Work Type: Hybrid, Full Time Job ID: 2612926 We’re building a relationship-oriented bank for the modern world. We need talented, passionate professionals who are dedicated to doing what’s right for our clients. At CIBC, we embrace your strengths and your ambitions, so you are empowered at work. Our team members have what they need to make a meaningful impact and are truly valued for who they are and what they contribute. What you'll be doing At CIBC US, we deliver tailored commercial and commercial real estate banking, private wealth management, personal and small business financial solutions, as well as cross-border banking services to clients with operations across North America. As the Director, US Sanctions Compliance, you'll report to the Head of Global Sanctions and play a pivotal role in overseeing the Second Line of Defense for sanctions risk in the US. You’ll serve as a subject matter expert on OFAC regulations and US sanctions frameworks, providing expert guidance across business lines, products, and jurisdictions. Your responsibilities include leading sanctions screening operations, ensuring regulatory compliance, and promoting a strong risk culture throughout the organization. You’ll collaborate closely with global sanctions partners to ensure alignment, engage stakeholders to foster awareness, and deliver targeted training to enhance sanctions risk expertise across the institution. At CIBC we enable the work environment most optimal for you to thrive in your role. At CIBC we enable the work environment most optimal for you to thrive in your role. You’ll have the flexibility to manage your work activities within a hybrid work arrangement where you’ll spend 3 days per week on-site, while other days will be remote. How you'll succeed - Program Leadership and Oversight – Lead the development and enhancement of the Sanctions Compliance Program, ensuring alignment with regulatory requirements and best practices. Own and maintain global and US sanctions compliance policies and standards. - Regulatory Engagement – Oversee and support regulatory examinations, internal audits, and testing reviews, including preparation of materials and drafting responses. Liaise with OFAC on licenses, voluntary self-disclosures, and regulatory inquiries, coordinating with internal and external legal partners. - Operational Effectiveness – Provide expert input on sanctions screening system tuning, threshold calibration, technology configurations, and list management. Offer practical guidance for new product reviews, client onboarding, alert escalations, payment structures, and complex transactions. - Cross-Functional Collaboration – Build strong partnerships with Technology, Data, and other risk management stakeholders to enhance program metrics and reporting. Engage with various risk teams and governance groups to promote and reinforce compliance standards. - Training and Awareness – Develop and deliver targeted training sessions to foster a strong culture of sanctions risk awareness. Maintain and deepen expertise in global sanctions regulatory requirements and industry developments. Who you are - You’re an experienced sanctions compliance leader. You bring at least 10 years of sanctions compliance experience with global financial institutions and have a deep understanding of multijurisdictional sanctions regimes (including US, Canada, EU, and UK). - You’re a strategic thinker. You have a proven ability to work independently, solve complex problems, and develop actionable insights to achieve objectives. - You’re a relationship builder. You excel at cross-functional project and relationship management, and you have experience mentoring junior compliance professionals. - You’re an effective communicator. You have exceptional written and verbal communication skills, enabling you to translate complex regulatory requirements into clear, actionable guidance. - You’re committed to continuous improvement. You demonstrate curiosity, collaboration, and openness to innovative approaches and industry best practices. - You’re proficient in technology. You’re comfortable using Microsoft Office products (Word, Excel, PowerPoint) to support your work. - Values matter to you. You bring your real self to work, and you live our values - trust, teamwork, and accountability. California residents — your privacy rights regarding your actual or prospective employment At CIBC, we offer a competitive total rewards package. This role has an expected salary range of $160,000- $190,000 USD for the market based on experience, qualifications, and location of the position (salary range varies based on the location which will be discussed at the time of the interview). The successful candidate may be eligible to participate in the relevant business unit’s incentive compensation plan, which may also include a discretionary bonus component. CIBC offers a full range of benefits and programs to meet our employee’s needs; including Medical, Dental, Vision, Health Savings Account, Life Insurance, Disability, and Other Insurance Plans, Paid Time Off (including Sick Leave, Parental Leave and Vacation), Holidays and 401(k), in addition to other special perks reserved for our team members. #LI-TA *This job is not eligible for employment sponsorship* What CIBC Offers At CIBC, your goals are a priority. We start with your strengths and ambitions as an employee and strive to create opportunities to tap into your potential. We aspire to give you a career, rather than just a paycheck. - We work to recognize you in meaningful, personalized ways including a competitive salary, incentive pay, banking benefits, a benefits program*, a vacation offering, wellbeing support, and MomentMakers, our social, points-based recognition program. - Our spaces and technological toolkit will make it simple to bring together great minds to create innovative solutions that make a difference for our clients. - We cultivate a culture where you can express your ambition through initiatives like Purpose Day; a paid day off dedicated for you to use to invest in your growth and development. *Subject to plan and program terms and conditions What you need to know - CIBC is committed to creating an inclusive environment where all team members and clients feel like they belong. We seek applicants with a wide range of abilities and we provide an accessible candidate experience. If you need accommodation, please contact Mailbox.careers-carrieres@cibc.com - You need to be legally eligible to work at the location(s) specified above and, where applicable, must have a valid work or study permit. - We may ask you to complete an attribute-based assessment and other skills tests (such as simulation, coding, MS Office). Our goal for the application process is to get to know more about you, all that you have to offer, and give you the opportunity to learn more about us. Job Location IL-Chicago, 70 W Madison St Fl 8 Employment Type Regular Weekly Hours 40 Skills Anti-Money Laundering (AML), Financial Transactions, Leadership, Operational Efficiency, People Management, Professional Presentation, Risk Management and Mitigation, Strategic Objectives

• Responsible for sound AML and Fraud risk management • Effective management of data, metrics, and reporting • Directly contribute and lead a team of professionals • Analyze various types of transactions and customer data • Develop reporting and analytics to support financial crime risk management • Build relationships with internal and external business partners

• Implements enterprise wide and business unit Anti-Money Laundering (AML) and Sanctions Programs to prevent illegal, unethical, or improper business practices • Assists in the execution and oversight of activities to comply with the Bank Secrecy Act, AML, USA PATRIOT ACT and Sanctions Program requirements • Updating AML and Sanctions policies and procedures as needed • Ensure that Compliance Manuals, Front Office Manuals, policies and procedures accurately reflect current laws, rules, other regulatory requirements and management intent • Independently challenges analyses, reviews and recommendations • Identify and define the AML and Sanctions objectives for assigned line(s) of business, products/services and applicable regulations • Communicate and socialize those objectives (from a leadership position) to the business • Coordinate AML and Sanctions compliance monitoring and oversee preparation of compliance reports • Prepare AML and Sanctions compliance reports and/or customer risk profiles • Identify issues and escalates through proper governance channels as needed • Analyze assessments of AML and Sanctions risk and internal controls • Research AML and Sanctions regulatory developments

• 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, and 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), and Enhanced Due Diligence (EDD) framework, including oversight of customer risk rating methodologies and ongoing monitoring activities. • Oversee the review and 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 and strategic guidance for complex investigations involving unusual activity, suspicious activity reporting (SAR), and regulatory reporting obligations. • Serve as the primary point of contact for regulatory examinations, independent audits, and compliance reviews related to BSA/AML and sanctions compliance, ensuring timely and effective remediation of identified issues. • Partner with Product, Engineering, Operations, Legal, and Risk teams to design scalable financial crime controls for new products, including consumer deposit and lending products. • Monitor regulatory developments and provide guidance on BSA, AML, sanctions, fraud, and related financial crime compliance requirements impacting Upstart’s business.