MLRO and Compliance Advisor

Job Description

Company Introduction

Job Responsibilities and Duties

• Act as the designated Money Laundering Reporting Officer (MLRO), serving as the primary contact with the FIAU and MFSA on AML/CFT and regulatory compliance matters;
• Review and investigate internal reports of suspicious activity, document findings and decisions, and submit Suspicious Transaction Reports (STRs) to the FIAU within the required timeframes;
• Coordinate regulatory submissions, including the annual Risk Evaluation Questionnaire (REQ), regulatory questionnaires and requests for information;
• Manage regulatory inspections, thematic reviews and external audits, ensuring that identified findings and required corrective actions are appropriately addressed;
• Prepare and present quarterly MLRO and Compliance reports, including relevant AML/CFT information, to the Board;
• Review and maintain AML/CFT policies, procedures and internal controls, conducting periodic assessments to identify regulatory gaps and areas for improvement;
• Oversee the preparation and ongoing review of business risk assessments, customer and jurisdictional risk methodologies, risk appetite statements and client risk registers;
• Evaluate the effectiveness of AML/CFT controls and risk management procedures, ensuring compliance with applicable legislation, regulatory guidelines and internal policies;
• Review and approve Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) documentation during onboarding and periodic reviews, obtaining senior management approval where required;
• Assess higher-risk client relationships, including decisions relating to acceptance, rejection or recommendations for termination where risks cannot be adequately mitigated;
• Evaluate source of funds and source of wealth information through supporting financial records, agreements and transaction documentation;
• Oversee ongoing client monitoring, sanctions and PEP screening, adverse media checks and enhanced monitoring of higher-risk relationships;
• Identify potential AML/CFT concerns, unusual transactions and inconsistencies in client activities, guiding relevant internal teams;
• Ensure ongoing compliance with the Company Service Providers Act, the MFSA CSP Rulebook and applicable Class C licence conditions;
• Develop and implement an annual risk-based Compliance Monitoring Programme, ensuring findings are documented, monitored and resolved;
• Maintain compliance policies and procedures covering conflicts of interest, outsourcing, record keeping, complaints handling and regulatory breach reporting;
• Monitor directorship and company secretarial appointments held by company officers, assessing potential conflicts of interest, time commitments and oversight responsibilities;
• Investigate and document compliance breaches and incidents, submitting regulatory notifications to the MFSA where necessary;
• Conduct due diligence on outsourced service providers and review related contractual arrangements;
• Deliver AML/CFT training to employees, maintain training records and promote awareness of regulatory responsibilities throughout the organisation;
• Monitor developments in Maltese and EU regulatory requirements, including the EU AML package and AMLA, and implement necessary updates to internal compliance frameworks;
• Oversee arrangements for Deputy MLRO or Designated Employee coverage to ensure continuity of the compliance function.

Experience

• Degree in Law, Finance, Accountancy, Business or a related field;
• Minimum 5 years of experience in AML/CFT or regulatory compliance within a Malta-regulated subject person, such as a corporate services provider, trustee, accounting or audit firm, bank or financial institution;
• Previous MFSA approval as an MLRO will be considered an asset, although candidates with equivalent practical AML/CFT and compliance advisory experience will also be considered;
• Professional certification in AML/CFT, such as ICA or ACAMS, will be considered an asset;
• Strong knowledge of the Prevention of Money Laundering Act (PMLA), Prevention of Money Laundering and Funding of Terrorism Regulations (PMLFTR), FIAU Implementing Procedures, EU AML Directives and the MFSA CSP Rulebook;
• Good understanding of applicable FATF Recommendations and MFSA regulatory expectations;
• Experience preparing or reviewing AML/CFT policies, risk assessments and compliance reports for Board-level consideration;
• Ability to meet the MFSA's fitness and properness requirements.

Personal Skills

• Strong analytical and investigative abilities, with excellent attention to detail;
• Excellent written and verbal communication skills, particularly when preparing regulatory correspondence and presenting compliance matters;
• Sound judgement and the ability to make independent, risk-based compliance decisions;
• Confidence in maintaining regulatory standards under commercial pressure while clearly communicating decisions to management and clients;
• Strong organisational skills with the ability to manage multiple regulatory obligations and deadlines;
• Ability to assess individual situations using a practical, risk-based approach;
• High level of integrity, professionalism and discretion when handling confidential information;
• A proactive, independent approach with a strong sense of accountability and responsibility.