MLRO / Deputy MLRO

POSITION OVERVIEW

Xapo is looking for a Money Laundering Reporting Officer (MLRO) or Deputy MLRO to join our global team, reporting to Xapo’s Chief Compliance Officer.The MLRO will drive the implementation and management of compliance controls, processes and operations for Xapo’s Anti-Financial Crime (AFC) Program, including its Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) activities. The MLRO/Deputy MLRO will work as an integral member of our global Compliance team, leveraging the broader organisation and resources to ensure that we maintain an effective AML/CTF program and meet all of our regulatory compliance obligations. This role will support the Chief Compliance Officer in the development and implementation of an AFC Framework which provides reasonable assurance that there are effective and efficient policies and procedures in place, which are well understood and respected by all Staff. This role will be based in Gibraltar where Xapo holds its regulatory authorisations.

RESPONSIBILITIES

• Ability to be approved by relevant regulatory authorities to hold the official MLRO and/or Nominated Officer role(s) for Xapo’s regulated entities, if required.
• Monitoring the regulatory landscape and documenting at least annually a regulatory risk assessment with recommendations based on the results (i.e. Annual Risk Assessment and MLRO’s Annual Report to the Board).
• Drafting Annual and Monthly Compliance Reports, and other such compliance reports as may be required.
• Maintain the AML Framework and AML policies and procedures to ensure the continued implementation of appropriate controls that reflect business and regulatory requirements.
• Oversee the AFC Compliance Monitoring Program comprised of daily, weekly, monthly and quarterly AFC compliance reviews.
• Facilitate risk-based Know Your Customer and Transaction Monitoring programmes to detect unusual activity and investigate and report suspicious activity in accordance to regulatory requirements, including the filing of Suspicious Activity Reports (SARs) and other such reports where appropriate.
• Planning, organization and execution of day-to-day operational activities and working with the business to remediate issues identified through testing and support.
• Execute a continuous improvement program driven by the outputs of Key Performance Indicators (KPIs) and Key Risk Indicators.
• Independently investigating and acting on matters related to AFC compliance.
• Build relationships with relevant authorities, payment schemes, card networks and regulators to ensure we operate in accordance with the latest AFC good practices.
• Supporting regulatory inquiries, filings and reporting requirements, ensuring accurate responses and reporting to the Regulator and other Authorities.
• Coordinating efforts related to audits, reviews, and examinations.
• Work with Compliance and Business leads to provide strategic planning, organisational structure, focus areas, and quarterly goals and key results.
• Conduct compliance review and analysis of new regulatory developments and maintain oversight of developments affecting business activities.
• Providing guidance, advice, and/or training and educational programs, to improve business understanding of related laws and regulatory requirements.

BASIC QUALIFICATIONS

• 8+ years of experience in banks, VASPs, complex financial services firms, or related e-money/payments industry with experience to operate at an MLRO or Deputy MLRO level.
• Strong operational knowledge in building and running a sound AFC compliance program, with hands-on knowledge and an understanding of regulatory requirements for Gibraltar in accordance with global AFC standards.
• 5+ years of people management experience would be desirable.
• Ability to build collaborative working relations with peers,...