岗位职责
We are seeking a seasoned Business AMLO (2 LOD) to serve as the primary AML risk owner for our Antom business lines. This role embeds AML expertise directly into business and product teams, ensuring financial crime controls are designed in from Day 1 of market entry and product development. This is a 2nd Line of Defense function — providing independent risk oversight while partnering closely with 1 LOD (Business Operations) to enable compliant, sustainable business growth. You will design compliant solutions for complex business scenarios, not just say "no" — while knowing when to escalate unacceptable risks. Balance efficiency, innovation, and regulatory compliance. Key Responsibilities
- New Market/Product Risk Assessment & Control Implementation ● Own New Market/Product Risk Assessments for market expansion initiatives (2 LOD independent assessment) ● Design and implement AML control frameworks tailored to local regulatory requirements and business models ● Drive Business Line Remediation initiatives where control gaps are identified ● Provide 2 LOD oversight on 1 LOD control implementation and execution ● Enable compliant market entry by designing pragmatic controls that support sustainable business growth
- Risk Appetite Alignment & Cross-Entity Risk Management ● Calibrate and align Risk Appetite across entities, ensuring consistency while accommodating local nuances (2 LOD independent calibration) ● Develop Business Line Risk Standards that balance compliance obligations with commercial viability ● Establish and improve Cross-Entity Risk Intelligence Sharing mechanisms
- Efficiency - Unified Standards & Experience ● Drive Unified Control Standards across markets to reduce fragmentation and operational complexity ● Ensure Consistent Customer/Business Experience — 2 LOD ensures AML controls enable, not obstruct, legitimate business ● Lead Process Optimization & Automation initiatives — leverage AI-driven data and systems to reduce manual effort ● Embed AML into product architecture and business processes through standards, processes, and technology — not just headcount ● Design compliant solutions for high-challenge business — support sustainable growth within regulatory boundaries
- Regulatory Partnership & Entity MLRO Collaboration ● Partner with Entity MLRO on regulatory matters — provide 2 LOD business context, risk assessments, and control evidence ● Collaborate on regulatory enquiries — prepare responses, gather documentation, and coordinate with business teams alongside Entity MLRO ● Ensure Entity AMLO and Business AMLO alignment on control design, regulatory expectations, and audit responses ● Monitor emerging regulatory requirements and ensure 2 LOD control frameworks evolve accordingly ● Support SAR governance, freezing orders, and regulatory filings in partnership with Entity MLRO ● Maintain independent escalation authority to Senior Management when risks exceed appetite
职位要求
Must-Have ● 10+ years in AML/CFT compliance, financial crime risk, or regulatory compliance ● Proven track record as Business AMLO (2 LOD) or equivalent — owned AML risk for a business/product portfolio ● Deep hands-on experience conducting New Market/Product risk assessments for market expansion ● Experience with merchant acquiring, payment services, or fintech business models ● Demonstrated success in embedding AML into product and business processes through standards and automation (2 LOD embedded model) ● Deep understanding of AML/CFT regulations across multiple jurisdictions (EMEA, APAC, US) ● Demonstrated ability to balance commercial pressure with regulatory requirements ● Excellent communication skills (written and verbal) in English Nice-to-Have ● Experience with Payment Institution / EMI licensing regulatory requirements ● Prior experience in high-growth fintech or payments scale-up ● CAMS or equivalent professional certification