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Head of AML (MLRO)

  • On-site
    • Birkirkara, Birkirkara, Malta
  • AML

Job description

Calamatta Cuschieri Moneybase plc is a privately held Fintech Group that operates in Investment Services, Fund Administration, Online Investing, and Payments. With roots dating back to 1971, the Group today is evolving at a fast pace whilst keeping the same core principles, that of providing clients the best service using the latest technology and the top professionals in their field, whilst ensuring the strong governance and ethics.

We are committed to attracting and selecting the very best people to join our team and to creating a workplace that promotes individual career growth; we value our people and their well-being. The group employs over 210 people from over 27 countries around the world with Assets Under Management and Administration of over 3 billion.



Summary of Position:

The Head of AML / MLRO is the designated officer under the PMLFTR responsible for receiving internal suspicion reports, deciding on onward disclosure to the FIAU, and acting as the principal point of contact with the FIAU, MFSA (on AML/CFT matters), and law enforcement. The role owns the AML/CFT framework end-to-end policy, risk assessment, monitoring, investigations, training, and regulatory reporting across Calamatta Cuschieri Moneybase.

The role requires a candidate who can operate confidently in both a payments/e-money environment, with working knowledge of AML/CFT considerations in investments services.The role is primarily focused on AML/CFT risks arising from payments activity and customer onboarding, with investment services exposure where applicable.


Duties & Responsibilities:

A. Statutory MLRO duties

  • Receive, assess, and investigate internal suspicion reports, and decide on onward disclosure to the FIAU in accordance with the PMLFTR.

  • Serve as the primary point of contact with the FIAU, including for tipping-off protocols, FIAU requests for information, and responses to sector reviews or supervisory exams.

  • Prepare and submit the annual MLRO report to each entity's Board under FIAU Implementing Procedures.

  • Submit the annual Risk Evaluation Questionnaire (REQ) and other regulatory reporting.

  • Ensure timely sanctions-related reporting to the Sanctions Monitoring Board as required.

B. AML/CFT framework ownership

  • Own, maintain, and periodically refresh the Business Risk Assessment (BRA) including sub-BRAs for product lines, channels, and geographies.

  • Own the Customer Risk Assessment methodology, including risk factor weighting, scoring, and customer risk re-tiering triggers.

  • Maintain and keep current the AML/CFT Policy, Customer Due Diligence Procedures, Enhanced Due Diligence Procedures, Transaction Monitoring Procedures, Sanctions Procedures, and PEP Procedures.

  • Design and oversee the second-line AML/CFT monitoring programme, including periodic testing of first-line controls.

  • Oversee the transaction monitoring system — rule calibration, alert investigation quality, backlog management, and tuning based on typologies.

  • Oversee sanctions screening — list management, screening scope, match quality, and escalation.

C. EMI / Payments / Investment specific duties

  • Oversight of AML controls on SEPA payments (SCT, SCT Instant, SDD), including Funds Transfer Regulation compliance on payer/payee information.

  • Oversight of fraud-AML interaction including mule account detection, account takeover scenarios, and first-party fraud.

  • Oversight of agent, distributor, and payment initiation service provider arrangements where applicable.

  • Monitoring of thematic payment risks — emerging typologies published by the EBA, FIAU, and FATF.

  • Oversight of onboarding processes including source of wealth and source of funds verification at onboarding and at trigger events.

  • Oversight of complex customer due diligence — corporate structures, trusts, nominee arrangements, and beneficial ownership.

  • PEP identification, EDD, senior management sign-off, and ongoing monitoring of PEP relationships.

  • Oversight of AML risks specific to the Italy branch and coordination with Italian AML requirements where applicable.

E. Governance, training, and reporting

  • Prepare annual MLRO report and periodic AML/CFT updates to each entity's Board.

  • Design and deliver AML/CFT training across the Group, including role-specific training for front-line staff, senior management, and Board members.

  • Own the Compliance Risk Assessment and Compliance Monitoring Programme as the AML/CFT subject matter expert.

  • Coordinate with the CCO, Head of Enterprise Risk, Internal Audit, and the MLROs of other Group entities to ensure framework consistency.

  • Act as the AML/CFT lead for regulatory examinations, FIAU supervisory visits, and internal audit reviews.

F. Regulatory change and horizon scanning

  • Lead the Group's readiness for the EU AML package (AMLR, AMLD6, AMLA) and provide regular updates to the Group.

  • Track and implement FIAU guidance updates, EBA AML guidelines, and FATF recommendations.

  • Assess the impact of crypto-asset Travel Rule obligations (TFR recast) and MiCA-adjacent AML developments where relevant to the Group.

  • Keep abreast on the developments in the upcoming PSD package and the interlink with AML.

Job requirements

  • Minimum 5 years’ AML/CFT experience within a regulated financial services environment, including at least 3 years in a senior AML role (MLRO, Deputy MLRO, Head of Financial Crime or similar)

  • Strong understanding of Maltese AML/CFT regulations, including FIAU Implementing Procedures and PMLFTR requirements

  • Experience within Payments, EMI, Banking, PSP or Fintech environments

  • Hands-on experience managing AML/CFT risks linked to payments, onboarding, transaction monitoring and financial crime typologies

  • Experience dealing directly with regulators and supporting supervisory reviews or regulatory inspections

  • Proven experience handling STR/SAR assessments and escalation decisions

  • Professional AML qualification such as ACAMS, ICA or equivalent

  • Strong experience assessing complex customer structures, corporate onboarding, UBO verification and enhanced due diligence

  • Able to operate in a fast-paced and evolving environment with a pragmatic and hands-on approach

  • Willing and able to undergo MFSA PQ assessment and FIAU notification process

Nice to Have

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  • Previous MLRO experience within Malta

  • Experience within investment services, asset management or MiFID environments

  • Exposure to crypto-asset AML and Travel Rule requirements

  • Experience implementing or scaling AML/CFT frameworks

  • Experience managing transaction monitoring systems and alert tuning programmes

  • Previous involvement in FIAU inspections or thematic reviews


Remuneration

We are committed to attracting and selecting top people to join our team. We are also committed to creating a workplace that encourages individual growth; we value our people and their well-being.


What we offer:

Attractive salary package including company Share Awards and Share Options

Annual Bonus linked to KPI

Health insurance and fitness allowances

Company parking

Study Leave

Fully paid sponsorship schemes for further studies

Exposure to the very latest technologies

Opportunities for career growth


Visit our cc.com.mt or moneybase.com for more information about our company

All Applications will be acknowledged and treated with maximum confidentiality

Reference: CCMT00826



“The enduring goal of Calamatta Cuschieri Moneybase is that the composition of our workforce should reflect that of the communities in which we work.”


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