Compliance Officer, Risk Officer and MLRO(Canada and US)

As Compliance Officer (both entities)

• Build, then keep current, each entity's written compliance program, with policies approved by a senior officer: client and beneficial-ownership due diligence, enhanced measures for higher-risk clients, record keeping, travel-rule data and training.
• Assess money laundering, terrorist financing and sanctions-evasion risk across clients, products, delivery channels and geographies, and assess new products, payment rails and corridors before launch.
• Set the outside compliance provider's scope, review its work and sign off what it produces.
• Run the written, ongoing training program and its training plan for staff and anyone acting for the entities.
• Keep each entity's registrations current: the money services business registration with FINTRAC and the payment service provider registration with the Bank of Canada in Canada; the FinCEN registration in the US, renewed every two years and re-filed within 180 days of a triggering change.
• Lead regulator examinations and requests for information, and answer due-diligence requests from banks, payout partners and clients.
• Monitor state money transmission licensing requirements for the US entity's activity, and advise the business before it enters a new state or product.

As MLRO (both entities)

• Run transaction monitoring and sanctions screening, and decide every escalated alert.
• Canada: file suspicious transaction reports with FINTRAC as soon as practicable after reasonable grounds to suspect are established, and terrorist property reports; oversee the prescribed reports, including international electronic funds transfers and virtual currency receipts of C$10,000 or more.
• US: file suspicious activity reports with FinCEN for suspicious transactions of US$2,000 or more within 30 days of initial detection, and keep them with their supporting documents for five years; oversee currency transaction reporting and OFAC blocking and reject reporting.
• Act as the contact for law enforcement requests and production orders, and protect the confidentiality of every report.

As Risk Officer (both entities)

• Canada: act as the senior officer who oversees the written risk management and incident response framework under the Retail Payment Activities Regulations, its incident reports and its third-party risk, and any safeguarding-of-funds framework if end-user funds are held.
• Canada: file the annual report to the Bank of Canada by March 31, and give notice of a significant change or new activity at least five business days before it happens.
• Maintain each entity's risk register and risk appetite, covering compliance, operational, third-party and partner risk, and report it to the board.
• Commission the independent reviews: FINTRAC's effectiveness review at least every two years, the Bank of Canada framework review at least every three years, and the US program's independent review; track every finding to closure.

Must have

• At least 7 years in anti-money-laundering and sanctions compliance at money services businesses, payment companies or the payments arm of a bank, including 3 or more as a compliance officer, MLRO or deputy.
• Deep knowledge of Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act and FINTRAC's guidance, and working knowledge of the Retail Payment Activities Act.
• Has built a compliance program, not only run one: written its policies, risk assessment and training plan.
• Has decided on and filed suspicious transaction reports, and has run transaction monitoring and sanctions screening.
• Has taken a business through a FINTRAC, bank-partner or audit examination and closed the findings.
• Due diligence on business clients, including clients that pay out for their own customers, and on banks and payout partners.
• A recognised AML certification, such as CAMS, or equivalent experience.
• Writes clearly for boards, regulators and banks, and works alone across time zones.
• Can pass the background checks regulators and banking partners require.

Can be learned here, or nice to have

• The US Bank Secrecy Act, FinCEN reporting and OFAC sanctions. Specialist support is available while you learn the US regime.
• Operational risk and incident response frameworks.
• Cross-border business payments with foreign exchange, or payments funded in stablecoins or other virtual currency, including the travel rule.
• US state money transmission licensing.
• Payout corridors in Asia-Pacific.
• Has managed outsourced compliance providers or set up monitoring and screening tools.
• Has been the officer of more than one entity at once.