• 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.

• Take ownership of the framework for continuous improvement of CDD methodology: onboarding & regular review. • Monitor account closures for integrity reasons and create controls in CDD to address the gaps in CDD methodology. • Work closely with the Machine Learning engineers on monitoring and continuous improvement of the accuracy of Customer Risk Assessment models. • Research new vendors and methods of conducting CDD and verification of customer identity. • Work closely with the Product Managers on the implementation of improvements to the CDD process: draft requirements, review product specifications for new CDD related features. • Draft guidance documents and provide regular training to 1LOD CDD team in relation to various risk elements of CDD. • Participation in Enterprise Wide Risk Assessment cycle by providing input on CDD related risks. • Initiate and take responsibility for ad hoc project work within the department. • Performing other duties as reasonably required for the operational efficiency of Finom.

• Take ownership of the framework for continuous improvement of CDD methodology: onboarding & regular review. • Monitor account closures for integrity reasons and create controls in CDD to address the gaps in CDD methodology. • Work closely with the Machine Learning engineers on monitoring and continuous improvement of the accuracy of Customer Risk Assessment models. • Research new vendors and methods of conducting CDD and verification of customer identity. • Work closely with the Product Managers on the implementation of improvements to the CDD process: draft requirements, review product specifications for new CDD related features. • Draft guidance documents and provide regular training to 1LOD CDD team in relation to various risk elements of CDD. • Participation in Enterprise Wide Risk Assessment cycle by providing input on CDD related risks. • Initiate and take responsibility for ad hoc project work within the department. • Performing other duties as reasonably required for the operational efficiency of Finom.