Head of Compliance, MLRO

This is a fully remote position, open to applicants in Kazakhstan.

📋 Description

• Act as the main liaison with relevant regulatory agencies.

• Ensure the organization complies with all applicable governance regulations, including fit and proper requirements for Approved and Designated Persons.

• Monitor and analyze regulatory changes pertinent to virtual assets, providing guidance to senior management and the Board as needed.

• Develop, implement, and uphold a comprehensive compliance framework that aligns with local regulations, FATF recommendations, and international best practices for virtual asset service providers (VASPs).

• Create, review, and revise all internal policies and procedures regarding AML/CFT, KYC, customer due diligence (CDD), enhanced due diligence (EDD), transaction monitoring, sanctions screening, data protection, cybersecurity compliance, and safeguarding client assets.

• Establish and manage the compliance monitoring program, including periodic testing, gap analysis, and reporting to senior management and the Board.

• Prepare and deliver regular compliance reports to the Board and relevant committees, covering regulatory changes, compliance breaches, and progress on remediation efforts.

• Serve as the designated MLRO, holding full statutory responsibilities for overseeing the organization's AML/CFT framework.

• Receive, evaluate, and assess all internal Suspicious Activity Reports (SARs) from team members, making informed decisions about whether to file external disclosures with appropriate local authorities.

• Manage and continually enhance the transaction monitoring program, with support from global compliance and product teams.

• Ensure thorough sanctions screening against all relevant lists, including OFAC, UK OFSI, UN, EU, and applicable local sanctions designations.

• Supervise customer risk scoring, risk-based KYC/CDD processes, and enhanced due diligence for high-risk clients, politically exposed persons (PEPs), and customers from high-risk jurisdictions.

• Be a vital member of the senior leadership team, contributing compliance insights on new products, services, partnerships, and business strategies.

• Promote a strong compliance culture throughout the organization via training, communication, and leading by example.

• Design and implement AML/CFT and compliance training programs for all employees, ensuring completion records are kept.

• Ensure that the organization’s compliance obligations are sufficiently resourced, advising the Board on staffing, systems, and budget needs.

• Establish and maintain a compliance manual and risk register, overseeing the escalation and resolution of compliance incidents and breaches.

• Prepare and submit all necessary regulatory reports and notifications to relevant authorities within designated timeframes.

• Maintain all compliance records, SAR documentation, KYC files, and transaction monitoring records in accordance with applicable retention standards.

• Provide support and facilitate any inspections, supervisory visits, or regulatory examinations.

⛳️ Requirements

• A Bachelor's degree in Law, Finance, Business, or a related discipline. A postgraduate qualification is a plus.

• A professional certification in compliance or AML is strongly recommended (e.g. CAMS, ICA Certificate/Diploma in AML or Compliance, CFE, or equivalent).

• At least 8 years of experience in compliance, AML, or financial crime prevention, including a minimum of 3 years in a senior or leadership compliance position.

• Proven in-house experience with virtual asset service providers (VASPs), cryptocurrency exchanges, fintech companies, or regulated financial institutions.

• Previous experience as an MLRO or Deputy MLRO is highly preferred.

• Experience in direct engagement with financial regulators.

• Practical experience in building compliance programs from the ground up in a start-up or scaling environment is a significant asset.

• Strong familiarity with the regional regulatory framework and requirements is highly preferred.

• In-depth understanding of FATF Recommendations and their application to virtual asset service providers, including the Travel Rule.

• Comprehensive knowledge of crypto-specific AML typologies.

• Proficiency in using blockchain analytics and transaction monitoring tools (e.g. Chainalysis, Elliptic, TRM Labs, or equivalent).

• Exceptional written and verbal communication skills in English and at least one regional language.

• Proficiency in Russian is a considerable advantage, given the regulatory landscape and relevant typologies for the role.

• Strong analytical and investigative capabilities, with the ability to clearly identify and articulate complex risk scenarios.

• Proven ability to engage constructively with regulators, external auditors, and law enforcement agencies.

• A high degree of personal integrity and sound professional judgment.

🏝️ Benefits

• Health insurance

• Professional development opportunities