Airwallex - Compliance Manager, MLRO
Requirements
• We’re looking for people who meet the minimum qualifications for this role. The preferred qualifications are great to have, but are not mandatory. • Education: Bachelor's Degree in Law, Finance, Business, or a related field is preferred. • Education: • Experience: 5+ years of experience in financial crime compliance with experience as an MLRO or Representante ante el SEPBLAC within a regulated financial institution, payment institution, or fintech operating in Spain or the broader EU/EEA market. • Regulatory Knowledge: Sound knowledge of Spanish AML/CTF obligations under Ley 10/2010 and RD 304/2014, the role of SEPBLAC as Spain's FIU and supervisory authority, the Órgano de Control Interno (OCI) framework, and Banco de España's oversight of payment institutions; familiarity with how EU AML Directives (AMLD4/AMLD5/AMLD6) and the forthcoming EU AML Regulation (EU) 2024/1624 apply in Spain. • Regulatory Knowledge: • Regulatory Exposure: Prior experience interacting with SEPBLAC and/or Banco de España, whether in a direct or supporting capacity (e.g., branch notifications, STR filings, regulatory correspondence, supervisory inspections). • Regulatory Exposure: • Operational Judgement: Demonstrated ability to manage suspicious activity escalations, STR filings via SEPBLAC's secure reporting platform, and to make sound, timely compliance decisions in a fast-paced commercial environment. • Operational Judgement: • Stakeholder Management: Ability to credibly engage internal stakeholders across compliance, legal, and commercial functions, and to represent Airwallex professionally before Spanish regulatory authorities. • Stakeholder Management: • Language: Business-level proficiency in both Spanish and English is required; the ability to conduct regulatory correspondence and draft compliance documentation in Spanish is essential. • Language: • Experience supporting a branch office or cross-border operation of a foreign-licensed financial institution or e-money institution in Spain, with an understanding of the DNB/SEPBLAC and DNB/Banco de España supervisory interface. • Experience in payments, fintech, or e-commerce, supporting cross-border products, card issuing/acquiring, or embedded finance use cases in the Spanish and/or EU market • Recognised professional certification in compliance or financial crime (e.g., CAMS, ICA Diploma, or CGSS). • Experience operating within a regional or global FCC function and partnering across multiple jurisdictions and time zones — particularly within the EU/EEA regulatory framework. • Prior exposure to EU and UN sanctions compliance frameworks and their application in a Spanish commercial context. • Familiarity with SEPBLAC's published sectoral guidance documents, typologies, and risk indicators, and their practical application within a payments/fintech business model. • Strong ability to build relationships and influence senior stakeholders across commercial and compliance functions, balancing business enablement with regulatory rigour. • Applicant Safety Policy: Fraud and Third-Party Recruiters • To protect you from recruitment scams, please be aware that Airwallex will not ask for bank details, sensitive ID numbers (i.e. passport), or any form of payment during the application or interview process. All official communication will come from an @airwallex.com email address. Please apply only through careers.airwallex.com or our official LinkedIn page. • Airwallex does not accept unsolicited resumes from search firms/recruiters. Airwallex will not pay any fees to search firms/recruiters if a candidate is submitted by a search firm/recruiter unless an agreement has been entered into with respect to specific open position(s). Search firms/recruiters submitting resumes to Airwallex on an unsolicited basis shall be deemed to accept this condition, regardless of any other provision to the contrary. • Equal opportunity • Equal opportunity
Responsibilities
• Regulatory Leadership & SEPBLAC Liaison • Serve as the designated MLRO and Representante ante el SEPBLAC for the Airwallex Spanish Branch, fulfilling local AML/CTF obligations under Ley 10/2010 and RD 304/2014, as applicable to a branch of a DNB-supervised institution operating in Spain. • Act as the primary local contact for SEPBLAC and Banco de España in respect of branch-level supervisory matters, regulatory notifications, and any correspondence or inspections relating to the Spanish Branch. • Support the EMEA Regulatory and Compliance team in managing the Spanish branch notification and approval process with the relevant Spanish authorities, and maintain ongoing compliance with any conditions or requirements attached to branch authorisation. • Local Compliance Oversight • Maintain ongoing FCC oversight of the Spanish Branch Office, ensuring that local activities remain within the approved branch perimeter and aligned to Airwallex NL's regulatory permissions. • Provide local compliance advice on Spain-based sales, marketing, and account management activity, ensuring that commercial activity is appropriately controlled and consistent with the Spanish Branch Office model. • Ensure that Spanish-specific AML/CTF and sanctions requirements under Ley 10/2010 and RD 304/2014 are appropriately reflected in local policies, procedures, escalation routes, training, governance, and reporting. • Commission or facilitate the periodic external expert review of the branch's AML programme required under Article 28 of RD 304/2014, and oversee remediation of any findings. • Suspicious Activity Reporting & SEPBLAC Engagement • Oversee local processes for identifying, escalating, assessing, and, where required, reporting suspicious activity (comunicaciones de operaciones sospechosas) to SEPBLAC via its secure reporting platform, in accordance with Articles 18–19 of Ley 10/2010. • Work closely with the EMEA FCC team to ensure that Spain-related suspicious activity is identified, investigated, escalated, and documented appropriately, in compliance with the tipping-off prohibition under Article 24 of Ley 10/2010. • Provide MLRO review and decision-making input on Spain-related suspicious activity, customer exits, account restrictions, law enforcement requests, and other financial crime risk outcomes where local Spanish input is required. • Commercial Enablement & Risk Advisory • Serve as the embedded compliance partner for the Spanish commercial and sales team, providing day-to-day regulatory guidance on customer queries, product use cases, and market-specific risk scenarios relevant to the Spanish and Southern European market. • Advise on Spanish market-specific compliance considerations for complex client engagements, ensuring appropriate escalation to the EMEA FCC and KYC Ops teams where required. • Support the assessment and launch of new products or commercial initiatives targeting the Spanish market, ensuring controls are proportionate and consistent with SEPBLAC expectations and Airwallex NL's risk appetite. • Governance & Reporting • Provide regular compliance MI and reporting to Airwallex NL senior management and relevant Group Risk Committees, covering branch-level risk indicators, regulatory developments, and the effectiveness of local controls. • Maintain and update the branch's formal risk assessment under RD 304/2014, ensuring it reflects the current risk profile of the Spanish Branch and is reviewed at least annually. • Fulfil any local reporting obligations to SEPBLAC or Banco de España arising from the branch's regulatory status, in coordination with Airwallex NL's Compliance and Legal teams. • Audit & Remediation • Audit & Remediation • Support the response to SEPBLAC and Banco de España branch-level supervisory enquiries, internal audits, and independent AML reviews, coordinating with the Internal Audit function where necessary. • Drive timely identification and remediation of any local compliance deficiencies, maintaining robust evidence of actions taken.
Apply in one click
Upload My Resume
Drop here or click to browse · Tap to choose · PDF, DOCX, DOC, RTF, TXT