Head of Financial Crime

The UK financial crime program is being built now, and it has to stand up to the FCA. This role sits in Compliance, reports to the US BSA/AML Officer, and owns the UK framework end to end — AML/CTF, sanctions, fraud, ABC, KYC/CDD/EDD, transaction monitoring, SARs, and the operating rhythm. You will still work the hard cases. It is a builder seat with accountability, not a queue job with “strategy” in the title.

If you have eight or more years inside an FCA-regulated bank, EMI, PI, or payments firm, have owned or rebuilt a financial crime control framework, and can still open a file, this is the seat. You will build the UK program from the ground up, setting the standards the team and the FCA will use. This is consumer-scale payments financial crime work – not a private-banking book – and you’ll sit directly with Product and Engineering. You’ll operate in a small team with a direct line to the US BSA/AML Officer, where scope is broad and process is lean. The measure of success is a program that still works a year later, and the role sits alongside MLRO / SMF17-adjacent duties for the UK entity.

• →Design and run the UK financial crime programme: policy, procedures, CDD/EDD, risk rating, sanctions screening, transaction monitoring, SAR handling, escalation, QA, and training
• →Turn MLR 2017, POCA, the Sanctions and Anti-Money Laundering Act, JMLSG, the FCA Financial Crime Guide, SYSC 6.3, and payments/EMI expectations into something operations and product can run
• →Own the UK business-wide risk assessment and keep it honest as the product, customer mix, and channels change
• →Handle complex cases — PEPs, adverse media, sanctions hits, high-risk onboarding, fraud typologies, escalations — then use the queue to fix the framework
• →Stand up first- and second-line controls: documentation, workflows, vendor oversight, quality sampling, MI, and issue management
• →Put UK requirements into the customer journey with Legal, Operations, Product, and Engineering. Be the UK voice in global design decisions
• →Report on quality, residual risk, throughput, and control health, and prepare the program for internal audit, skilled-person reviews, and FCA scrutiny
• →Build the operating model as the team grows.
• →Hire, coach, and set the standard
• →Support MLRO / SMF17-adjacent duties as the UK permissions model requires

• 8+ years of hands-on experience with financial crime in a regulated UK firm (bank, EMI, PI, payments, or e-money), including substantial KYC/CDD/EDD

• You will still do the cases, close gaps in a small team, do not wait for a 30-page RACI
• You know the UK regime well enough to argue a point — MLR 2017, JMLSG, POCA, UK sanctions, FCA expectations — and how it lands in a payments product
• You have designed or rebuilt a framework, procedure, or control, not only cleared files or written a policy nobody ran
• You have led people or a workstream. You can defend a risk decision and explain it to the Product without jargon
• EU financial crime experience
• Experience with the EU AML package, 6AMLD, EBA guidelines, national transposition, or an EU FIU/regulator, especially on cross-border payments, wallets, or EMI/PI products (useful because X Money will not stay inside one perimeter)

• In-office five days a week; occasional work-from-home when needed