The Bank
A leading issuing bank, who has been transforming the future of cross border payments to serve our Clients over the past 18 years. The Bank has recently embarked on a journey to expand its banking product range and now offers digital corporate banking services locally.
The Bank has offices in London, Malta and Gibraltar, currently serving innovative Clients through a portfolio of e-money products and payment services as well as deposit accounts for its Corporate Clients. As a leader in the industry, we set the standard for excellence in the payments sector. We are forward thinkers in a complex ecosystem and partner with cutting edge Fintech’s to challenge the way we conventionally bank for the better.
Investors
Our parent company, IDT Corporation, is an innovative and opportunity-seeking multinational company headquartered in the US and listed on the New York Stock Exchange, with offices across the globe.
Role Outline
The MLRO & Head of Financial Crime is responsible for leading the Bank's Financial Crime function and fulfilling the statutory responsibilities of the approved Money Laundering Reporting Officer (MLRO). The role provides strategic oversight of the Bank's anti-money laundering, counter terrorist financing, counter proliferation financing, sanctions and fraud risk frameworks, ensuring effective systems and controls are maintained to meet legal, regulatory and internal governance requirements.
The role leads the Financial Crime Team, providing direction, oversight and subject matter expertise across the Bank's corporate banking and payment services activities. Working closely with senior management, business functions and regulators, they will be responsible for promoting a strong financial crime compliance culture, and ensuring the Bank's financial crime framework remains robust, proportionate and aligned with regulatory expectations.
Main Responsibilities
• Regulated individual, subject to approval from the GFSC to act as the Bank’s MLRO, fulfilling all statutory responsibilities under applicable AML, CTF, CPF and Sanctions legislation, regulations and regulatory guidance.
• Oversee the investigation and escalation of unusual and suspicious activity, including receiving and determining internal suspicious activity reports, submitting external Suspicious Activity Reports (SARs) to the relevant FIU, where appropriate.
• Act as the Bank's principal point of contact with the Financial Intelligence Unit, GFSC, law enforcement agencies and other competent authorities on matters relating to suspicious activity reporting and MLRO responsibilities.
• Prepare and submit all mandatory regulatory returns, statutory notifications and MLRO reports required by applicable legislation and regulatory requirements.
• Provide regular reports to the Board and senior management committees regarding the effectiveness of the Bank's AML/CFT/PF framework, material financial crime risks, significant incidents, suspicious activity reporting, sanctions matters and emerging regulatory developments.
• Lead, manage and develop the Financial Crime Prevention Team, ensuring appropriate resourcing, technical capability, and continuous professional development to deliver an effective and proportionate second line Financial Crime function.
• Oversee the effectiveness of financial crime systems and controls, including transaction monitoring, sanctions screening, name screening, and customer risk scoring, ensuring appropriate testing, tuning, calibration, optimisation and periodic effectiveness reviews are undertaken.
• Own and oversee the Bank's Financial Crime Framework, including AML, CTF, CPF, financial sanctions, fraud risk management and associated financial crime prevention controls, ensuring they remain effective, proportionate and aligned to regulatory requirements.
• Own and maintain the Bank's Financial Crime policies, standards, procedures and supporting documentation, ensuring they remain current, reflect legislative and regulatory developments, industry best practice and the Bank's evolving risk appetite.
• Oversee the identification, assessment, monitoring and mitigation of financial crime risks across all business activities, including new products, services and jurisdictions.
• Maintain effective oversight of the Bank's customer due diligence, enhanced due diligence, ongoing monitoring and customer risk assessment frameworks, ensuring compliance with applicable regulatory requirements and internal risk appetite.
• Support business areas in understanding their Financial Crime related risks and how to implement appropriate systems and controls to mitigate those risks. This includes acting as SME on key projects as designated by the business.
• Develop and oversee the Bank's Financial Crime Training Programme, ensuring all employees receive appropriate role-based training.
Competencies, Knowledge & Skills
• Strong working knowledge of UK, Gibraltar and, EEA, AML,CTF, CPF, sanctions and fraud legislation, regulations and regulatory guidance.
• Previous experience as an approved regulated MLRO (or equivalent controlled function) within a regulated financial services business.
• Demonstrable experience of operating, overseeing or optimising financial crime technology, including transaction monitoring, sanctions screening, customer risk assessment and case management systems.
• Experience analysing management information, financial crime data, trends and key risk indicators to identify emerging risks and support risk-based decision-making.
• Ability to provide effective second line oversight, independent challenge and assurance over the Bank's financial crime framework and control environment.
• Excellent analytical, investigative and decision-making skills, with the ability to assess complex financial crime matters and exercise sound judgement.
• Ability to work independently, exercise sound judgement and manage competing priorities whilst delivering to demanding regulatory and business deadlines. Strong leadership and people management experience, preferably gained within a banking or payments environment.
Additional Skills Required
• Professional mannerism
• Self-motivated and able to work with a team to complete necessary tasks in a timely manner
• Pro-active approach to daily duties
• Ability to take initiative and utilise sound judgment in decision-making
• Agile and pragmatic when approaching change
• Adaptable to a wide range of products and variables when assessing risk
• Good oral and written communication skills
The holder of this position will be expected to pass the required background checks in line with the Bank’s policy.
Disclaimer
The above statements are intended to describe the general nature and level of work being performed by people assigned to this classification. They are not to be construed as an exhaustive list of all responsibilities, duties, and skills required of personnel so classified. All personnel may be required to perform duties outside of their normal responsibilities from time to time, as needed