Anti-Money Laundering Manager

Anti-Money Laundering Manager (MLRO)

Function: Money Laundering Reporting Function

Reporting to: Chief Executive Officer & Board (via Audit & Risk Committee)

Role Purpose

The Anti-Money Laundering Manager (MLRO) is the designated officer responsible for ensuring full compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations in accordance with the QFCRA AML/CFTR Rulebook.

The role is accountable for designing, implementing, and continuously enhancing the organization’s AML/CTF framework, including policies, procedures, transaction monitoring, staff training, and regulatory reporting.

The MLRO acts as the primary liaison with regulators, including the QFCRA and Qatar Financial Information Unit (FIU), ensuring the firm maintains the highest standards of financial crime compliance, safeguarding its reputation, and supporting the integrity of its operations across local and international markets.

Key Responsibilities

AML/CTF Governance & Framework

• Develop, implement, and maintain a robust AML/CTF Compliance Framework aligned with QFCRA AML/CFTR requirements
• Ensure the framework is tailored to the firm’s business model including investment advisory, fund structures, SPVs, cross-border transactions, and correspondent relationships
• Establish and periodically review the firm’s Risk-Based Approach (RBA) covering customer, geographic, and transactional risks

Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

• Oversee client onboarding including identity verification, source of funds/wealth, and beneficial ownership
• Review and approve high-risk clients including PEPs and complex ownership structures
• Ensure periodic KYC reviews in line with regulatory requirements

Transaction Monitoring & Investigations

• Oversee transaction monitoring systems across all business lines
• Investigate suspicious activities and alerts
• Prepare and submit Suspicious Transaction Reports (STRs) to FIU with proper documentation

Regulatory Engagement & Reporting

• Act as the main point of contact with QFCRA and FIU
• Prepare and submit regulatory reports including Annual AML Return
• Manage regulatory inspections and communications
• Report material AML breaches as per regulatory requirements

Training & Awareness

• Develop and deliver AML/CTF training programs
• Promote awareness of emerging risks including sanctions evasion and complex ownership structures
• Evaluate training effectiveness and update programs accordingly

Cross-Border Oversight & Correspondent Banking

• Ensure AML compliance across international transactions and investments
• Conduct AML due diligence on counterparties and partners
• Advise on onboarding entities in high-risk jurisdictions
• Oversee AML controls across group entities and affiliates

Monitoring, Testing & Record Keeping

• Conduct testing of AML controls and ensure remediation of gaps
• Maintain accurate AML records including KYC, STRs, and policies
• Update Business Risk Assessment (BRA) and Compliance Monitoring Plan (CMP)

Qualifications & Experience

• Bachelor’s degree in Law, Finance, Risk Management, or related field
• CAMS, ICA or equivalent AML certification preferred
• 8–10 years of experience in financial crime compliance including senior AML/MLRO exposure
• Experience in investment firms or financial institutions preferred
• Strong knowledge of QFCRA regulations and FATF standards

Core Competencies

• Strong knowledge of AML/CTF regulations and global practices
• Analytical and investigative skills
• Strong judgment and decision-making ability
• Stakeholder management and regulatory communication
• High integrity and discretion

Regulatory Requirements

Must be approved as an Approved Individual by QFCRA (or equivalent) demonstrating fitness and propriety, technical competence, independence, and sufficient authority within the organization