AVP, Group FCC Lead

Location: Delhi, India
 Reporting line: Group Financial Crime Compliance Division
 Level: Assistant Vice-President
 Experience: 8 to 12 years in Financial Crime Compliance

• Tazapay operates a regulated cross border payments group with multiple MLROs across different jurisdictions. The Senior Manager, Group FCC will provide a consistent and expert review point for high risk customer decisions, critical escalations and customer risk assessments across the group.

• The role will support each entity MLRO by exercising delegated approval authority within agreed thresholds, applying strong judgement to complex customer and transaction risk issues, and ensuring that decisions are properly documented, evidenced and capable of regulatory or audit review.

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  High risk customer approvals: Review, approve, decline or escalate high risk customer onboarding and periodic reviews referred by Compliance Operations, including PEPs, sanctions or adverse media concerns, higher risk industries and jurisdictions, complex ownership structures and sensitive business models.

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  Critical escalations: Act as the second line review point for material escalations before they are referred to the relevant MLRO, including transaction monitoring alerts, sanctions matches, internal suspicion reports, law enforcement requests and other significant FCC matters.

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  Customer risk assessment validation: Validate customer risk assessments for high risk files before they are submitted to the relevant MLRO. Ensure that risk ratings, rationale, mitigating controls and approval recommendations are clear, consistent and supported by evidence.

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  Monthly reporting to MLROs: Provide each MLRO with a monthly summary of decisions taken for their entity, including approvals, declines, exits, PEP decisions, sanctions related matters, critical escalations, open issues and key trends. Meet with each MLRO monthly to review the pack and capture any challenge or feedback.

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  Country and industry risk framework: Maintain and refresh the Group Country Risk Assessment and Industry Risk Assessment frameworks, taking into account FATF outputs, sanctions developments, regulatory expectations, typologies and emerging financial crime risks.

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  Compliance monitoring and reporting: Monitor FCC operational performance across the group, identify control gaps or recurring quality issues, and track remediation actions arising from quality assurance, internal audit, regulatory findings or management review.

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  Training and support: Support FCC training across the group, with particular focus on helping India based teams identify, assess and escalate risks across the jurisdictions they support.

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  Support to MLRO reporting: Assist MLROs with annual compliance reports, regulatory submissions and management reporting by providing data, analysis and insight drawn from customer risk decisions and escalation trends.

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  New product and market expansion review Provide FCC input on new payment corridors, product launches and merchant segment expansions before/ after go-live, identifying financial crime risks, recommending controls and ensuring that FCC requirements are met..

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  Regulatory Change Management — Monitor regulatory developments across all jurisdictions in which the Group operates, assess the impact of new rules, guidance, and FATF outputs on Group FCC policies and procedures, and coordinate implementation of required changes with the relevant MLROs and operational teams in a timely manner.

• 10 to 12 years of FCC experience in a regulated financial institution, bank, payments firm, e-money institution or similar regulated business.

• Strong experience in high risk customer reviews, enhanced due diligence, PEP assessments, sanctions related decisions, adverse media analysis, source of funds and source of wealth review.

• Experience working in a second line FCC role, with the ability to make balanced, well reasoned and audit ready decisions.

• Multi jurisdictional exposure, ideally including at least two of Singapore, India, Hong Kong, UAE, Australia, Canada, Lithuania, the European Union, the United Kingdom or the United States.

• Strong working knowledge of AML, CFT and sanctions frameworks, FATF standards, cross border payments typologies and customer risk assessment methodology.

• Professional certification such as CAMS, ICA Diploma, ACAMS Advanced or equivalent is preferred.

• Strong judgement, with the confidence to make decisions under uncertainty and the discipline to escalate where appropriate.

• Excellent written reasoning, with the ability to produce clear, concise and defensible decision records.

• Methodical approach, with the ability to separate evidence from assumption and identify gaps in analysis.

• Strong stakeholder management skills, including the ability to work effectively with MLROs, Compliance Operations, Legal, Risk and business teams.

• Operational discipline, cultural awareness and the ability to work across multiple jurisdictions, time zones and regulatory expectations.

Education:
University Graduates 
Added advantage with the certification Professional certification such as CAMS, ICA Diploma, ACAMS Advanced or equivalent is preferred.