Compliance Officer, MLRO

Time zone
Anywhere 🌎
Full Time
Opening date
Closing date
16 Jun 2021


This job has now closed and is no longer accepting applications.

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Archive Job Description

Xapo is an international fintech startup on a mission to protect and grow its clients’ life savings.

We’re a fully distributed team that works remotely from 50+ countries around the world. We may come from many different cultures and backgrounds, but it’s our values, our resourcefulness, and our drive that makes us Xapiens.

We work hard, think globally, and inspire each other to grow every day. If you’re the best at what you do and share our passion, we want you.

Join us, wherever you are, and help us build a digital bank worthy of the digital age at Xapo.

Position overview

Xapo is looking for a Money Laundering Reporting Officer (MLRO) or Deputy MLRO to join our global team, reporting to Xapo’s Chief Compliance Officer.The MLRO will drive the implementation and management of compliance controls, processes and operations for Xapo’s Anti-Financial Crime (AFC) Program, including its Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) activities.

The MLRO/Deputy MLRO will work as an integral member of our global Compliance team, leveraging the broader organisation and resources to ensure that we maintain an effective AML/CTF program and meet all of our regulatory compliance obligations. This role will support the Chief Compliance Officer in the development and implementation of an AFC Framework which provides reasonable assurance that there are effective and efficient policies and procedures in place, which are well understood and respected by all Staff.

Ideally, this role will be based in Gibraltar where Xapo holds its regulatory authorisations; however, inasmuch as Xapo is a global business and this role is critical to Xapo’s success, outstanding candidates based outside of Gibraltar will also be considered.


  • Ability to be approved by relevant regulatory authorities to hold the official MLRO and/or Nominated Officer role(s) for Xapo’s regulated entities, if required.
  • Monitoring the regulatory landscape and documenting at least annually a regulatory risk assessment with recommendations based on the results (i.e. Annual Risk Assessment and MLRO’s Annual Report to the Board).
  • Drafting Annual and Monthly Compliance Reports, and other such compliance reports as may be required.
  • Developing the AFC Framework and AFC policies and procedures to ensure the implementation of appropriate controls that reflect business and regulatory requirements.
  • Developing and implementing the AFC Compliance Manual (i.e. AFC Compliance Policies & Procedures).
  • Developing and implementing the AFC Compliance Monitoring Program comprised of daily, weekly, monthly and quarterly AFC compliance reviews.
  • Facilitate risk-based Know Your Customer and Transaction Monitoring programmes to detect unusual activity and investigate and report suspicious activity in accordance to regulatory requirements, including the filing of Suspicious Activity Reports (SARs) and other such reports where appropriate.
  • Overseeing the operations of the AFC Compliance team, including training, capacity planning, tracking team and individual Key Performance Indicators (KPIs), and Key Risk Indicators (KRIs) for the program.
  • Planning, organization and execution of day-to-day operational AFC compliance activities and working with the business to remediate issues identified through testing and support.
  • Independently investigating and acting on matters related to AFC compliance.
  • Build relationships with relevant authorities, payment schemes, and regulators to ensure we operate in accordance with the latest AFC good practices.
  • Supporting regulatory inquiries, filings and reporting requirements, ensuring accurate responses and reporting to the Regulator and other Authorities.
  • Coordinating efforts related to audits, reviews, and examinations.
  • Overseeing the operations of the AFC Compliance team, including training, capacity planning, tracking team and individual Key Performance Indicators (KPIs), and Key Risk Indicators (KRIs) for the program.
  • Work with Compliance and Business leads to provide strategic planning, organisational structure, focus areas, and quarterly goals and key results
  • Work with all relevant partners, financial institution partners, card networks and regulatory authorities
  • Conduct compliance review and analysis of new regulatory developments and maintain oversight of developments affecting business activities.
  • Providing guidance, advice, and/or training and educational programs, to improve business understanding of related laws and regulatory requirements.

Basic qualifications

  • 10+ years of experience in banks, complex financial services firms, or related e-money/payments industry with experience to operate at an MLRO or Deputy MLRO level
  • Strong operational knowledge in building and running a sound AFC compliance program, with hands-on knowledge and an understanding of regulatory requirements for Gibraltar in accordance with global AFC standards.
  • 5+ years of people management experience.
  • Ability to build collaborative working relations with peers, colleagues and with remote based teams with individuals at all levels of the organisation.
  • Experience with AFC system implementation, configuration and management.
  • Experience with data visualisation tools.
  • Crypto currency experience and AFC program management.

Other requirements

  • A dedicated workspace.
  • A reliable internet connection with the fastest speed possible in your area.
  • Devices and other essential equipment that meet minimal technical specifications.
  • Alignment with Our Values.

Why work for xapo?

  • Impact globally, work remotely.
  • Shape the Future: Improve lives through cutting-edge technology, work 100% remotely from anywhere in the world.
  • Own Your Success: Receive attractive remuneration, enjoy an autonomous work culture and flexible hours, apply your expertise to meaningful work every day.
  • Expect Excellence: Collaborate, learn, and grow with a high-performance team.

About xapo

We founded Xapo to address two of the biggest issues with Bitcoin adoption: accessibility and security. In a matter of years, we developed an industry-leading platform that introduced cryptocurrency into the daily lives of millions worldwide.

Now, we’re bringing our expertise to all facets of our users’ finances. Because no matter who we are or where we’re from, we all deserve more options, more control, and more peace of mind where our money is concerned.

We’re an Equal Opportunity Employer – we believe that diversity is critical to our success as a global company. An inclusive workplace is the foundation of Xapo – it allows us to create products that cater to clients around the world.

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