Key Responsibilities
- Support, maintain, and execute an independent, risk-based AML/CTF compliance monitoring and testing programme across BBSA’s EMI and CASP perimeter.
- Perform thematic and control effectiveness reviews covering CDD/EDD, transaction monitoring, sanctions/PEP screening, recordkeeping, and governance arrangements.
- Independently assess the adequacy and effectiveness of first-line controls and document conclusions with clear ratings and recommendations.
- Issue formal findings, agree remediation actions with the First Line of Defence (1LoD), and independently validate remediation closure through follow-up testing.
- Escalate material weaknesses or control deficiencies to senior management and governance committees where required.
- Provide second-line review and challenge of higher-risk cases escalated by the first line (high-risk customers, complex typologies, sanctions/PEP matches, internal escalation); support MLRO decisioning and documentation.
- Conduct or support independent investigations triggered by red flags, audit/regulatory findings, or intelligence from partners; ensure a consistent audit trail in case management tools.
- Oversee and coordinate responses to police, law enforcement, and competent authority requests in collaboration with the MLRO and Legal.
- Provide compliance oversight to ensure responses are timely, complete, proportionate, and aligned with regulatory obligations.
- Maintain governance-level logs, metrics, and reporting relating to external authority requests.
- Assess whether information requests or intelligence received may indicate systemic control weaknesses or trigger enhanced monitoring requirements.
- Draft, maintain, and periodically review AML/CTF policies, procedures, and standards for the EMI and CASP perimeter (risk rating, CDD/EDD, transaction monitoring governance, sanctions/PEP, record retention etc.).
- Contribute to the AML/CTF Business Risk Assessment and annual compliance plan; support governance committees and management reporting.
- Provide AML/CTF advisory support to Operations, Onboarding, Product, and Engineering teams (new products/process changes, control design, risk mitigations).
- Support the development and delivery of AML/CTF training and communications, including targeted guidance for high-risk scenarios.
- Support responses to CSSF requests, audits, and inspections; prepare monitoring reports, management information (MI/KRIs), and remediation tracking.
- Stay up to date on changes to AML/CTF laws, CSSF guidance, and financial crime typologies relevant to payments and crypto-asset services.
Key Requirements
- Education: Bachelor’s degree in Law, Compliance, Finance, Business Administration, or a related field.
- Experience: At least 4 years of experience in AML/CTF Compliance (second line of defence/compliance monitoring), preferably within an EMI/PI, CASP/VASP, bank, or regulated fintech environment. Demonstrated experience drafting AML/CTF policies and procedures, executing compliance monitoring/testing, supporting MLRO investigations and STR/SAR processes, and handling police/law-enforcement information requests.
- At least 4 years of experience in AML/CTF Compliance (second line of defence/compliance monitoring), preferably within an EMI/PI, CASP/VASP, bank, or regulated fintech environment.
- Demonstrated experience drafting AML/CTF policies and procedures, executing compliance monitoring/testing, supporting MLRO investigations and STR/SAR processes, and handling police/law-enforcement information requests.
- Skills: Strong understanding of AML/CTF governance, the three lines of defence model, and second-line compliance monitoring methodologies. Excellent analytical and investigative skills, with the ability to produce clear written assessments and regulatory-ready documentation. Ability to take full ownership of projects from conception to completion within agreed timelines. Proficiency with AML tooling (case management, screening, transaction monitoring); familiarity with blockchain analytics tools is an advantage. Strong communication skills, both written and verbal, in English; French is an asset; knowledge of German and/or Luxembourgish is an advantage.
- Strong understanding of AML/CTF governance, the three lines of defence model, and second-line compliance monitoring methodologies.
- Excellent analytical and investigative skills, with the ability to produce clear written assessments and regulatory-ready documentation.
- Ability to take full ownership of projects from conception to completion within agreed timelines.
- Proficiency with AML tooling (case management, screening, transaction monitoring); familiarity with blockchain analytics tools is an advantage.
- Strong communication skills, both written and verbal, in English; French is an asset; knowledge of German and/or Luxembourgish is an advantage.
- Certifications: Relevant certifications such as CAMS (Certified Anti-Money Laundering Specialist) or ICA (International Compliance Association) qualifications are considered an advantage.
- At least 4 years of experience in AML/CTF Compliance (second line of defence/compliance monitoring), preferably within an EMI/PI, CASP/VASP, bank, or regulated fintech environment.
- Demonstrated experience drafting AML/CTF policies and procedures, executing compliance monitoring/testing, supporting MLRO investigations and STR/SAR processes, and handling police/law-enforcement information requests.
- Strong understanding of AML/CTF governance, the three lines of defence model, and second-line compliance monitoring methodologies.
- Excellent analytical and investigative skills, with the ability to produce clear written assessments and regulatory-ready documentation.
- Ability to take full ownership of projects from conception to completion within agreed timelines.
- Proficiency with AML tooling (case management, screening, transaction monitoring); familiarity with blockchain analytics tools is an advantage.
- Strong communication skills, both written and verbal, in English; French is an asset; knowledge of German and/or Luxembourgish is an advantage.
