Head of Compliance & AMLCO

We are looking for a Head of Compliance & AMLCO to lead the compliance and AML/CTF function for a Cyprus-regulated Electronic Money Institution. You will also act as the designated AML Compliance Officer under the Central Bank of Cyprus requirements, serve as the primary point of contact with the Central Bank of Cyprus, and ensure the licence remains in good standing as the business grows and its control framework matures.

Responsibilities

Strategy & Leadership

• Act as the designated Head of Compliance / AMLCO under the applicable Cyprus regulatory requirements. 

• Own the company's compliance and AML/CTF strategy, setting the direction for how the function operates and evolves as the business grows.

• Advise the Board, CEO, and senior management on regulatory risks, emerging obligations, and the company's compliance posture. 

• Define the company's risk appetite for financial crime and make sure it's reflected in policies, controls, and day-to-day decisions across the business.

• Build and lead the compliance function, including managing outsourced compliance arrangements and holding third-party providers to clear performance standards.

• Work through a compliance culture across the organisation where obligations are understood at every level and where people come to compliance early.

Regulatory Oversight & CBC Relationship

• Act as the designated AMLCO under the Electronic Money Laws of 2012 and 2018, carrying full responsibility for the company's AML/CTF framework before the CBC.

• Own the relationship with the Central Bank of Cyprus - managing all supervisory correspondence, leading the company's response to thematic reviews and on-site visits, and maintaining a constructive and transparent relationship with the regulator.

• Ensure the company's licence remains in good standing at all times, identify and address any conditions or requirements proactively, before they become issues.

• Oversee the full regulatory reporting calendar - PIEMI RR Forms, quarterly and semi-annual payment statistics, AMLCO annual reports, AML and sanctions risk assessments, and the Annual Compliance Declaration - taking responsibility for their accuracy and timeliness.

AML/CTF Framework

• Update as necessary and maintain the company's end-to-end AML/CTF framework: Customer Acceptance Policy, CDD and EDD procedures, transaction monitoring programme, sanctions screening controls, Travel Rule compliance, and SAR/STR reporting to MOKAS.

• Conduct and maintain enterprise-wide AML and sanctions risk assessments, ensuring they reflect the company's actual risk profile and are updated when material changes occur.

• Receive, assess, and act on internal suspicious activity reports; make final decisions on external disclosures to MOKAS with clear documentation.

• Drive continuous improvement of transaction monitoring and sanctions screening systems - challenging false positive rates, coverage gaps, and system effectiveness on an ongoing basis.

Governance & Controls

• Develop and run the annual Compliance Monitoring Programme: set the testing scope based on risk, document outcomes clearly, assign remedial actions to accountable owners, and track delivery.

• Assess conflict of interest risks arising from employees holding dual roles across group entities; maintain the Conflicts of Interest Register and make sure genuine risks are escalated and managed.

• Oversee initial and annual assessments of outsourced compliance and AML providers, ensuring arrangements are properly documented and performance is reviewed.

• Work with the internal auditor to agree findings, direct the company's remediation response, and track implementation through to closure.

• Produce clear, substantive reporting to the Board and senior management on financial crime risks, compliance monitoring outcomes, and open regulatory matters.

People & Culture

• Set and deliver the company's AML/CTF training programme, making sure content reflects current regulatory expectations and is relevant to the roles being trained.

• As the business grows, recruit and develop compliance team members, building a function capable of supporting expanded operations

Requirements

• Proven track record leading a compliance and AML function at Head, AMLCO, or equivalent level within a CBC regulated entity - EMI, payment institution.

• Deep knowledge of the Electronic Money Laws of 2012 and 2018, the CBC's AML/CTF Directive including the 2025 update, applicable EU AML Directives, and FATF recommendations.

• Direct experience owning the CBC supervisory relationship - leading responses to thematic reviews, managing on-site visits, and handling sensitive regulatory correspondence.

• Ability to operate at Board level: presenting clearly, challenging constructively, and translating complex regulatory requirements into decisions management can act on.

• Strong grasp of EMI prudential requirements - PIEMI RR reporting, capital adequacy frameworks, and client fund safeguarding obligations.

• Experience designing and improving transaction monitoring and sanctions screening programmes, including managing system performance and reducing false positive rates.

• Demonstrated ability to build compliance frameworks from the ground up or restructure existing ones as a business evolves.

• Holds or is working towards a relevant professional AML qualification - such as ICA, ACAMS, or equivalent - accepted as evidence of competence for the AMLCO role; prior CBC approval as AMLCO is a strong advantage.

• Degree in Law, Finance, Economics, or a related field; postgraduate qualification is an advantage.

• Fluency in English.