岗位职责
Team Introduction In line with the globalization strategy and vision of the company, the Global Payments team builds a platform to provide cross-border payment solutions for all ByteDance's products and services, that are growing rapidly worldwide. About the Role We are seeking a Compliance Lead with hands-on experience running and leading a compliance function within a Non-Bank EMI, digital bank, or fintech in the Philippines. The role concurrently serves as the entity's designated Money Laundering Reporting Officer (MLRO), with the specific mandate of reviewing, agreeing, and confirming STR filings prepared by the Financial Crime / Investigations team — investigations and case build-out remain with that team; the MLRO is the final approver of filing decisions. Beyond the MLRO function, this role is the local compliance lead who partners closely with regional and global compliance teams across APAC and HQ, translating Philippine regulatory requirements into actionable guidance for product, operations, and policy stakeholders, and ensuring local rules are accurately reflected in regional frameworks, controls, and rollouts. The ideal candidate has a strong working knowledge of the AMLA (RA 9160, as amended), its IRRs, the BSP MORNBFI, AMLC Registration and Reporting Guidelines (ARRG), and GoTRACS filing standards, and is conversant with regulatory developments in digital payments, e-wallets, cross-border remittance, VASPs, and BNPL in the Philippines. This position reports to the Chief Compliance Officer, Philippines, who oversees compliance for both payments and financial services for the Philippines business. This role will be based onsite at our office and will require a 5-day onsite work arrangement. Responsibilities Compliance Officer (Core) - Support the Chief Compliance Officer in ensuring the EMI complies with applicable laws, regulations, and supervisory expectations issued by the BSP, AMLC, SEC, and other relevant authorities. - Develop, implement, and maintain the entity's compliance program, policies, and procedures, including the MTPP / AML/CFT program, training, and compliance-awareness initiatives tailored to Non-Bank EMI activities. - Ensure timely and accurate submission of compliance-related regulatory reports to the BSP, AMLC, and other regulators. - Provide pragmatic compliance advisory to Product, Engineering, Operations, Customer Service, Treasury, and Marketing on new product launches, partnerships, customer journeys, and changes to flows of funds. - Identify, assess, and manage regulatory and AML/CFT risks; lead/contribute to the entity's Institutional Risk Assessment (IRA) and EWRA across customer, product, channel, geography, and transaction-risk dimensions. - Support licensing and ongoing regulatory workstreams (EMI license maintenance, product approvals, material-change notifications, outsourcing/cloud notifications). - Serve as a working-level point of contact for BSP and AMLC, supporting examinations, RFIs, supervisory letters, and remediation commitments under the CCO's direction. Regional Coordination & Advisory - Act as the bridge between Philippines compliance and the regional/global compliance teams (APAC and HQ), proactively communicating local regulatory developments, BSP/AMLC circulars, and enforcement trends. - Translate Philippine local requirements into clear, actionable guidance for regional product, policy, legal, and operations teams; review regional policies, standards, and templates for local applicability and gap-fit. - Participate in regional compliance forums and working groups, contributing local perspective on AML/CFT, sanctions, consumer protection, data privacy, and licensing topics. - Advise on cross-border product rollouts (e.g., remittance, wallet interoperability, partner integrations) to ensure Philippine touchpoints meet local requirements while staying aligned with regional frameworks. - Coordinate local input into regional reporting, risk dashboards, and management information to senior leadership. MLRO (Filing Confirmation Only) - Serve as the designated MLRO for the Non-Bank EMI before the AMLC. - Review and confirm/agree on STR filings prepared and investigated by the Financial Crime / Investigations team, including assessing sufficiency of the investigation file, suspicion rationale, typology codes, narrative quality, and supporting documentation, and approve/decline filing accordingly. - Authorize and oversee submission of agreed STRs (and other AMLC-mandated reports such as CTRs) through GoAML / goTRACS, ensuring filings meet AMLC quality and timeliness standards. - Maintain a clear audit trail and rationale for each filing decision (including no-file outcomes), and act as the formal point of accountability for filings during AMLC, BSP, and audit reviews. - Provide feedback to the Investigations team on filing trends, typology gaps, and quality observations to support continuous improvement (without taking over investigation work).
职位要求
Minimum Qualifications - Bachelor's degree in Law, Finance, Accounting, Business, or related discipline. - 5+ years of regulatory and AML/CFT compliance experience, with substantive time in digital payments (Non-Bank EMI / OPS) or financial services (digital bank, fintech, lending, BNPL) in the Philippines. - Experience dealing with the BSP and/or AMLC, including responding to RFIs and participating in examinations. - Strong understanding of Philippine financial regulations, particularly those issued by BSP and AMLC, and of AML/CFT requirements applicable to EMIs. - Experience conducting regulatory risk assessments / EWRA and developing compliance policies and procedures. - Demonstrated ability to coordinate with regional or global compliance teams and clearly communicate local regulatory requirements to non-local stakeholders. - Comfortable navigating a fast-paced, ambiguous, high-growth fintech environment; self-starter with strong ownership. Preferred Qualifications - CAMS certification (or equivalent — CFCS, ICA Diploma) preferred. - Prior experience as a designated MLRO or Deputy MLRO, specifically in the filing-approval capacity (reviewing/confirming STRs prepared by an investigations team). - Prior tenure with a regulator (BSP, AMLC, SEC) or with a top-tier consulting financial-crime advisory practice. - Experience supporting BSP examinations and AMLC compliance checks, including drafting management responses and tracking remediation. - Familiarity with FATF Recommendations, APG Mutual Evaluation findings on the Philippines, and the Philippines' FATF grey-list exit roadmap. - Working knowledge of the Data Privacy Act (RA 10173) and the Financial Consumer Protection Act (RA 11765) as they intersect with EMI operations.
