Quick overview
Job description
This is the first compliance hire for our North American businesses: a Canadian and a US money services business in a regulated payments group. You will hold three roles at both entities: Compliance Officer, Risk Officer, and Money Laundering Reporting Officer (MLRO). The job is to build the programs, then run them.
Both businesses are early. They move money across borders for business clients, with foreign exchange where needed, and their volumes are starting now. You will work with a small team and can bring in outside providers for monitoring and reviews, working under your direction.
What You Will Do
- Build, then keep current, each entity's written compliance program: client and beneficial-ownership due diligence, enhanced measures for higher-risk clients, record keeping, travel-rule data, and training.
- Assess money laundering, terrorist financing, and sanctions-evasion risk across clients, products, channels, and geographies, and assess new products, payment rails, and corridors before launch.
- Set the outside compliance provider's scope, review its work, and sign off what it produces.
- Run the ongoing staff training program, and keep each entity's registrations current with FINTRAC, the Bank of Canada, and FinCEN.
- Lead regulator examinations and information requests, and answer due-diligence requests from banks, payout partners, and clients.
- Monitor US state money transmission licensing requirements and advise the business before it enters a new state or product.
- Run transaction monitoring and sanctions screening, and decide every escalated alert.
- Canada: file suspicious transaction and terrorist property reports with FINTRAC, and oversee the other prescribed reports.
- US: file suspicious activity reports with FinCEN, and oversee currency transaction reporting and OFAC blocking and reject reporting.
- Act as the contact for law enforcement requests and production orders, and protect the confidentiality of every report.
- Canada: act as the senior officer overseeing the risk management and incident response framework under the Retail Payment Activities Act, including incident reports, third-party risk, and any safeguarding-of-funds framework.
- Canada: file the annual report to the Bank of Canada by March 31, and give notice of significant changes or new activity ahead of time.
- Maintain each entity's risk register and risk appetite across compliance, operational, third-party, and partner risk, and report to the board.
- Commission the independent reviews required under each regime, and track every finding to closure.
As Compliance Officer
As MLRO
As Risk Officer
What we expect from you
- At least 7 years in anti-money-laundering and sanctions compliance at money services businesses, payment companies, or the payments arm of a bank, including 3 or more as a compliance officer, MLRO, or deputy.
- Deep knowledge of Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act and FINTRAC's guidance, and working knowledge of the Retail Payment Activities Act.
- Experience building a compliance program, not only running one: policies, risk assessment, and training plan.
- Experience deciding on and filing suspicious transaction reports, and running transaction monitoring and sanctions screening.
- Experience taking a business through a FINTRAC, bank-partner, or audit examination and closing the findings.
- Due diligence experience on business clients, including clients that pay out for their own customers, and on banks and payout partners.
- A recognised AML certification, such as CAMS, or equivalent experience.
- Clear writing for boards, regulators, and banks, and the ability to work alone across time zones.
- Able to pass the background checks that regulators and banking partners require.
Must have
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