The demand splits into three employer shapes. The first is a bank. PNC Financial Services Group’s Form 10-K for the year ended December 31, 2025, filed February 20, 2026, states that the company is headquartered in Pittsburgh and that consolidated total assets were $573.6 billion, total deposits $440.9 billion, and total shareholders’ equity $60.6 billion. The same filing classifies PNC and PNC Bank as Category III banking organizations: more than $250 billion and less than $700 billion of consolidated assets, not a global systemically important bank, and less than $75 billion of cross-jurisdictional activity. PNC Bank is a national bank supervised primarily by the Office of the Comptroller of the Currency. The holding company is supervised by the Federal Reserve. Those facts locate a BSA program. They are not a statement that Sartori recruits the bank’s own staff, and they are not a vacancy count.
The regulation that names the person is older than the filing. Under 31 CFR 1020.210, a bank regulated by a federal functional regulator meets the Bank Secrecy Act program statute if the program includes designation of an individual or individuals responsible for coordinating and monitoring day-to-day compliance. The FFIEC BSA/AML manual says the board designates that officer, and it cites 12 CFR 21.21(d)(3) for the OCC. The manual is explicit that the act of designation does not, by itself, make the program adequate. The officer needs authority, independence, and resources matched to the bank’s risk, and a report of compliance status to the board or a committee the board names. OCC Bulletin 2025-37, issued November 24, 2025, sets community-bank BSA examination procedures for examinations beginning February 1, 2026. Those procedures are for community banks. A Category III national bank is outside that bulletin. A brief that copies the community-bank manual into the job description has already chosen the wrong officer.
The second shape is the covered health system, and it is not the BSA seat. UPMC’s year-end report for calendar 2025 says the system is based in Pittsburgh, that operating revenues were $33.563 billion for the year ended December 31, 2025, and that it has more than 40 hospitals and 800 clinical locations. The revenue is system-wide. It includes insurance enrollment as well as patient care, and it is not a Pittsburgh-only slice. Title 45 CFR 164.530 requires a covered entity to designate a privacy official who develops and implements its privacy policies, and a contact person or office for complaints. That official is not the person 31 CFR 1020.210 names. A health-system brief that asks one hire to be both the privacy official and a bank BSA officer is asking for two licenses, two regulators, and two reporting lines. Of the 2 Pittsburgh compliance seats inside the firm-wide 36, 1 was a privacy official at a health system and 1 was a BSA officer at a bank headquartered in Pittsburgh. Those two numbers add to the 2.
The third shape is the issuer whose chief compliance officer will be read against the Evaluation of Corporate Compliance Programs, updated 2024. Prosecutors test design, good-faith application, and whether the program works in practice. Authority, resources, and independence are part of that test. The officer who has sat an examination asks which committee receives the report before asking about the title. When the open chair is the general counsel of an energy company rather than the compliance officer, the brief moves to energy general counsel search. That energy search is a different mandate, and it is not a second Pittsburgh compliance count.
The Philadelphia interview cohort attached to the envelope is 250 structured interviews. It is one cohort for that city. The scorecard in week one, before any name is discussed, is short.
- Which function. BSA officer under 31 CFR 1020.210, privacy official under 45 CFR 164.530, chief compliance officer read against the 2024 Evaluation of Corporate Compliance Programs, or more than one of those, named separately.
- Which supervisor is actually on the file. OCC for a national bank, the Federal Reserve for the holding company, and the Department of Health and Human Services for a covered entity are not the same examination.
- Which manual. OCC Bulletin 2025-37 applies to community-bank examinations beginning February 1, 2026. PNC’s 10-K classifies the institution as Category III. The bulletin is the wrong job description for that category.
- Which admission, if any. The 8,688 active attorneys are Allegheny County in the 2025 Annual Report. A BSA officer who will not practice law does not need the Rule 302 license. Requiring it shrinks the pool to a different profession. The 420 In-House Corporate Counsel licenses are statewide.
- Which cash cell. The $133,040 median is SOC 23-1011 lawyers in the Pittsburgh MSA. It is not a CCO band, and it is not the $234,916 common pleas salary.