The Money Laundering Reporting Officer (MLRO) & Sanctions Officer is responsible for ensuring that Airbnb Payments UK Limited (APUK) payments entity is working in line with AML regulations; supporting, delegating and deputising for the Chief Compliance Officer (CCO);  assisting the CCO in creating, maintaining and executing the Compliance Monitoring Plan; and ensuring reporting under policy and governance remains at an optimum level. 

Ideally the successful candidate has a working experience in financial crime prevention, financial crime risk management, or transaction monitoring and SAR Filing at a financial institution, coupled with detailed knowledge of the relevant FCA principles and rules, UK Money Laundering Regulations, and UK JMLSG Guidance notes. 

Regulatory Scope: PSD2, AMLD5, Payment Services Directive, UK AML/CFT and OFSI Regulations, Data Protection and Privacy/GPDR 

Responsibilities: 

• Support the enhancement of the AML governance framework in line with business strategy and act in a MLRO capacity, assisting the CCO with all aspects of AML, market abuse, financial crime and regulatory engagement 
• Arranging and coordinating with the US team to ensure service levels and  deadlines are met
• Acting as AML/CTF subject matter expert and helping to drive enhanced technical knowledge and expertise in the APUK Compliance team
• Leading the collation and submission of external AML, Sanction and Financial Crime returns; and the collation and drafting of internal Financial Crime reporting,  including reports to the Management Committee, Payment Risk and Compliance Committee and the Board 
• Overseeing and evolving the existing Financial Crime control framework across  both 1st and 2nd lines of defence to ensure it keeps pace with strategic growth plans 
• Developing and implementing policies and procedures, as well as reviewing and approving high risk accounts
• Preparing and submitting AML related returns to the FCA , OFSI and NCA as required 
• Building strong and productive stakeholder relationships, providing subject matter expertise, AML and sanction advice for the day-to-day operational processes, and assisting with the development of appropriate policies, manuals, and  procedures 
• Leading and developing the APUK AML, Sanction and SAR governance agenda and act as the central point for AML and sanction related queries
• Act as a Nominated Officer for suspicious activity reports (SARs), building out the  responsibilities and ensuring reviews are undertaken and fully documented
• Development of Key Risk Indicators (KRIs) and relevant controls across lines of business
• Ensuring that products and services offered by the business are compliant with AML and sanction regulatory requirements and company procedures
• Oversight of AML and transaction monitoring and pro-actively managing Financial  Crime prevention activities in line with the ‘3 lines of defence’ model, liaising with other 2nd line colleagues to ensure a robust and comprehensive AML governance framework
• Significantly contribute to enhanced compliance risk monitoring by identifying and developing appropriate/relevant metrics that examines the adequacy of payments compliance systems and controls; and by leading on regulatory mapping enhancement opportunities by identifying gaps, recommending clear requirements to First-line teams and tracking resolution
• Second-line program-level ownership of APUK SAR filing program which includes delivering detailed, data-driven narratives to inform CCO, Legal and the Board of risk levels/mitigations/impacts; coordinating with the Global Compliance team and Airbnb Capability Centre (ACC) team in India to fulfil APUK’s SAR reporting obligations by filing and tracking reports to the UK FIU;  and overseeing performance and quality of outsourced transaction monitoring operations
• Lead and deliver enhanced Law Enforcement engagement strategy, aligning with Global Compliance team, AP Lux team and Legal team, on issues or opportunities, appropriate solution and plan to implement solutions/best practices for responding to sensitive external requests such as requests for information and data, production, and restraint orders
• Be the point of escalation for managing complex suspicious activity investigations and/or high risk compliance issues from legal, Compliance or other business  teams. Apply knowledge of regulatory knowledge to recommend solutions and consulting with the CCO when appropriate
• Knowledge sharing – working with key stakeholders to ensure an ongoing programme of education in terms of AML requirements and regulatory expectations 
• Provision of coaching and mentoring of other members of the compliance  team as and when required / identified

Requirements:

• Minimum five years of relevant experience in financial services/payment  services, regulatory agency, consultancy, or law firms working on financial crime risk or regulatory compliance 
• In depth working knowledge of all applicable legislation and regulation relating to  an EMI or other Payment firm including but not limited to JMLSG, FCA, EU,  FATF, OFSI, UK Bribery Act and any other applicable legislation/rules relating to  AML and sanction
• Demonstrable experience of leading best practice in Customer Due Diligence (CDD) and sanctions monitoring, customer risk assessment, and high-risk  customer case reviews
• Financial sector experience and a wider understanding of how the regulatory landscape is implemented across Financial Services
• Understanding of the FCA and PRA’s supervisory frameworks 
• Understanding of AML/CTF legislation and its application in the UK and FCA supervisory regime
• Committed to getting things done, ability to meet deadlines, prioritize workloads, maintain attention to detail, resolve issues, and work in a fast-paced and rapidly changing environment while working independently 
• Ability to translate complex issues for consumption by technical and non technical audiences at all levels. Candidate should be able to compose succinct, rational and grammatically correct documents
• Excellent team player with the ability to work closely with others to deliver results, identify and resolve issues, and keep team members and management informed
• Ability to influence others and lead on large and complex projects involving  multiple stakeholders
• Proven ability to take ownership, self-motivate and deliver results in highly ambiguous environments
• The ability and willingness learn new skills and ramp quickly to new  requirements
• Excellent written and verbal communication skills, including executive level presentations

Preferred Qualifications:

• People Management experience
• Related Compliance qualification (ACAMS/ICA), or willingness to obtain
• Advanced Excel skills