Original listing text, shown exactly as published by the company.
Responsibilities
Strategy & Leadership
- Act as the designated Head of Compliance / AMLCO under the applicable Cyprus regulatory requirements.
- Own the company's compliance and AML/CTF strategy, setting the direction for how the function operates and evolves as the business grows.
- Advise the Board, CEO, and senior management on regulatory risks, emerging obligations, and the company's compliance posture.
- Define the company's risk appetite for financial crime and make sure it's reflected in policies, controls, and day-to-day decisions across the business.
- Build and lead the compliance function, including managing outsourced compliance arrangements and holding third-party providers to clear performance standards.
- Work through a compliance culture across the organisation where obligations are understood at every level and where people come to compliance early.
Regulatory Oversight & CBC Relationship
- Act as the designated AMLCO under the Electronic Money Laws of 2012 and 2018, carrying full responsibility for the company's AML/CTF framework before the CBC.
- Own the relationship with the Central Bank of Cyprus - managing all supervisory correspondence, leading the company's response to thematic reviews and on-site visits, and maintaining a constructive and transparent relationship with the regulator.
- Ensure the company's licence remains in good standing at all times, identify and address any conditions or requirements proactively, before they become issues.
- Oversee the full regulatory reporting calendar - PIEMI RR Forms, quarterly and semi-annual payment statistics, AMLCO annual reports, AML and sanctions risk assessments, and the Annual Compliance Declaration - taking responsibility for their accuracy and timeliness.
AML/CTF Framework
- Update as necessary and maintain the company's end-to-end AML/CTF framework: Customer Acceptance Policy, CDD and EDD procedures, transaction monitoring programme, sanctions screening controls, Travel Rule compliance, and SAR/STR reporting to MOKAS.
- Conduct and maintain enterprise-wide AML and sanctions risk assessments, ensuring they reflect the company's actual risk profile and are updated when material changes occur.
- Receive, assess, and act on internal suspicious activity reports; make final decisions on external disclosures to MOKAS with clear documentation.
- Drive continuous improvement of transaction monitoring and sanctions screening systems - challenging false positive rates, coverage gaps, and system effectiveness on an ongoing basis.
Governance & Controls
- Develop and run the annual Compliance Monitoring Programme: set the testing scope based on risk, document outcomes clearly, assign remedial actions to accountable owners, and track delivery.
- Assess conflict of interest risks arising from employees holding dual roles across group entities; maintain the Conflicts of Interest Register and make sure genuine risks are escalated and managed.
- Oversee initial and annual assessments of outsourced compliance and AML providers, ensuring arrangements are properly documented and performance is reviewed.
- Work with the internal auditor to agree findings, direct the company's remediation response, and track implementation through to closure.
- Produce clear, substantive reporting to the Board and senior management on financial crime risks, compliance monitoring outcomes, and open regulatory matters.
People & Culture
- Set and deliver the company's AML/CTF training programme, making sure content reflects current regulatory expectations and is relevant to the roles being trained.
- As the business grows, recruit and develop compliance team members, building a function capable of supporting expanded operations
Requirements
- Proven track record leading a compliance and AML function at Head, AMLCO, or equivalent level within a CBC regulated entity - EMI, payment institution.
- Deep knowledge of the Electronic Money Laws of 2012 and 2018, the CBC's AML/CTF Directive including the 2025 update, applicable EU AML Directives, and FATF recommendations.
- Direct experience owning the CBC supervisory relationship - leading responses to thematic reviews, managing on-site visits, and handling sensitive regulatory correspondence.
- Ability to operate at Board level: presenting clearly, challenging constructively, and translating complex regulatory requirements into decisions management can act on.
- Strong grasp of EMI prudential requirements - PIEMI RR reporting, capital adequacy frameworks, and client fund safeguarding obligations.
- Experience designing and improving transaction monitoring and sanctions screening programmes, including managing system performance and reducing false positive rates.
- Demonstrated ability to build compliance frameworks from the ground up or restructure existing ones as a business evolves.
- Holds or is working towards a relevant professional AML qualification - such as ICA, ACAMS, or equivalent - accepted as evidence of competence for the AMLCO role; prior CBC approval as AMLCO is a strong advantage.
- Degree in Law, Finance, Economics, or a related field; postgraduate qualification is an advantage.
- Fluency in English.
