Serve as the primary point of contact with relevant regulatory bodies. - Ensure the organisation meets all applicable governance requirements, including fit and proper obligations for Approved and Designated Persons. - Monitor and interpret regulatory developments relevant to virtual assets, and advise senior management and the Board accordingly. ### Compliance Programme Development & Management
Design, implement, and maintain a comprehensive compliance framework aligned with local requirements, FATF recommendations, and international best practice for virtual asset service providers (VASPs). - Develop, review, and update all internal policies and procedures covering AML/CFT, KYC, customer due diligence (CDD), enhanced due diligence (EDD), transaction monitoring, sanctions screening, data protection, cybersecurity compliance, and safeguarding of client assets. - Establish and oversee the compliance monitoring programme, including periodic testing, gap analysis, and reporting to senior management and the Board. - Prepare and present regular compliance reports to the Board and relevant committees, including on regulatory changes, compliance breaches, and remediation progress. ### AML/CFT & MLRO Duties
Act as the designated MLRO, with full statutory responsibility for overseeing the organisation's AML/CFT framework. - Receive, review, and assess all internal Suspicious Activity Reports (SARs) from staff, and make informed decisions on whether to file external disclosures with competent local authorities. - Oversee and continuously improve the transaction monitoring programme, with support from global compliance and product functions. - Ensure robust sanctions screening against all applicable lists, including OFAC, UK OFSI, UN, EU, and applicable local sanctions designations. - Oversee customer risk scoring, risk-based KYC/CDD processes, and enhanced due diligence for high-risk customers, politically exposed persons (PEPs), and customers from high-risk jurisdictions. ### Governance & Culture
Act as a key member of the senior leadership team, providing compliance input on new products, services, partnerships, and business initiatives. - Champion a strong compliance culture across the organisation through training, communications, and leadership by example. - Design and deliver AML/CFT and compliance training programmes for all staff, ensuring completion records are maintained. - Ensure that the organisation's compliance obligations are adequately resourced, and advise the Board on staffing, systems, and budget requirements. - Establish and maintain a compliance manual, risk register and oversee the escalation and resolution of compliance incidents and breaches. ### Reporting & Recordkeeping
Prepare and submit all required regulatory reports and notifications to relevant authorities within stipulated deadlines. - Ensure that all compliance records, SAR documentation, KYC files, and transaction monitoring records are maintained in accordance with applicable retention requirements. - Support and facilitate any inspections, supervisory visits, or regulatory examinations. ## What We Look For in You
Qualifications
Bachelor's degree in Law, Finance, Business, or a related field. A postgraduate qualification is advantageous. - Professional certification in compliance or AML is strongly preferred (e.g. CAMS, ICA Certificate/Diploma in AML or Compliance, CFE, or equivalent). ### Experience
Minimum of 8 years of experience in compliance, AML, or financial crime prevention, with at least 3 years in a senior or leadership compliance role. - Demonstrated in-house experience working within virtual asset service providers (VASPs), cryptocurrency exchanges, fintech firms, or regulated financial institutions. - Prior experience as an MLRO or Deputy MLRO is highly desirable. - Experience engaging directly with financial regulators. - Hands-on experience building compliance programmes from the ground up in a start-up or scaling environment is a significant advantage. - Familiarity with the regional regulatory framework and requirements is strongly preferred. ### Knowledge & Skills
Deep understanding of FATF Recommendations and their application to virtual asset service providers, including the Travel Rule. - Strong knowledge of crypto-specific AML typologies. - Proficiency with blockchain analytics and transaction monitoring tools (e.g. Chainalysis, Elliptic, TRM Labs, or equivalent). - Excellent written and verbal communication skills in English and at least one regional language. - Proficiency in Russian is a significant advantage given the regulatory environment and the typologies relevant to the role. - Strong analytical and investigative skills, with the ability to identify and articulate complex risk scenarios clearly. - Demonstrated ability to engage constructively with regulators, external auditors, and law enforcement. - High degree of personal integrity and sound professional judgment. ## Nice to Have
Experience in cryptocurrency or blockchain compliance programs. - Familiarity with compliance technology and analytics tools. - Prior exposure to multi-jurisdictional compliance oversight. ## Additional Notes
This role will be subject to fit and proper assessment as part of the licensing process. Candidates must be prepared to undergo background checks, provide regulatory questionnaires, CVs, references, and proof of relevant qualifications. Prior enforcement history, regulatory sanctions, or unexplained gaps in professional record may affect eligibility. Notice:
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