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Deputy MLRO

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Our client is a leading global digital assets platform seeking a Deputy Money Laundering Reporting Officer (Deputy MLRO) to strengthen its UAE compliance and financial crime framework.


Reporting to the UAE MLRO, this individual will play a central role in shaping and executing the firm’s AML, CTF, sanctions, and broader financial crime strategy across its UAE-regulated entities, with a particular focus on crypto, digital assets, and high-velocity payment flows.

The role is suited to a seasoned financial crime professional who combines strong technical AML knowledge of the UAE regulatory landscape with the ability to operate as a pragmatic business partner in a fast-paced, product-driven environment.


Key Responsibilities

Support to the MLRO & Regulatory Interface

  • Act as a senior deputy and trusted adviser to the UAE MLRO in all AML, CTF, sanctions, and financial crime matters.
  • Assist in managing day-to-day engagement with relevant UAE regulators (e.g. CBUAE, VARA, DFSA, FSRA , and other competent authorities as applicable), including responses to enquiries, inspections, thematic reviews, and audits.
  • Prepare, review, and where appropriate support the MLRO in filing regulatory reports , including STRs/SARs to the UAE Financial Intelligence Unit (FIU) via goAML, and other mandated submissions.
  • Help ensure that the firm remains up to date with UAE AML/CFT legislation , implementing regulations, guidance, and expectations specific to virtual assets / crypto, and that these are embedded into internal policies and procedures.


AML / CTF Framework & Governance

  • Co-own, with the MLRO, the design, maintenance and continuous enhancement of the AML/CTF compliance programme , tailored to the risks inherent in digital assets, cross-border flows, and new products.
  • Support the development and periodic review of the Business Risk Assessment and AML Risk Assessment , ensuring that emerging risks (e.g. DeFi, darknet exposure, mixers, privacy coins) are captured and reflected in controls.
  • Draft, review, and periodically update policies, standards, and procedures covering KYC / CDD, EDD, ongoing monitoring, sanctions screening, PEP handling, transaction monitoring, and suspicious activity reporting.
  • Contribute to the preparation of MLRO reports to senior management and the Board, providing clear, data-led insight into financial crime risk, control performance, and remediation status.


Client Due Diligence & Onboarding

  • Oversee, with the MLRO, the implementation of risk-based KYC/CDD frameworks for retail, institutional, and high-risk clients, ensuring alignment with UAE regulatory expectations for VASPs / crypto exchanges.
  • Provide second-line advisory to onboarding and sales teams on complex cases, including high-risk geographies, corporate structures, source of wealth/funds, and crypto-specific risk indicators.
  • Review and, where required, sign off on high-risk client approvals , EDD packs, and periodic reviews, ensuring decisions are consistent, well documented, and defensible to regulators and auditors.


Transaction Monitoring, Investigations & Reporting

  • Help manage the transaction monitoring framework , including rules design, calibration, tuning, and periodic model validation, with a specific lens on blockchain analytics and on/off-ramp behaviour.
  • Oversee the handling of alerts, investigations, and case management, ensuring that suspicious activity is identified, escalated, documented, and reported to the FIU in a timely and robust manner.
  • Leverage blockchain analytics and other intelligence tools to detect typologies such as chain-hopping, layering, mixer usage, ransomware proceeds, sanctions evasion, and market abuse relevant to digital assets.
  • Drive quality and consistency in investigation files , ensuring they withstand regulatory scrutiny and internal audit review.


Sanctions, Screening & Name Matching

  • Support the MLRO in designing and operating the sanctions and screening programme , including real-time and batch screening of customers, transactions, and wallet addresses against relevant sanctions lists and watchlists.
  • Oversee complex sanctions-related investigations and escalations, ensuring a defensible and well-governed approach to list matches, potential breaches, and reporting obligations.
  • Maintain close awareness of global sanctions developments impacting crypto and digital assets, and help translate them into clear internal requirements.


Strategy, Advisory & Change

  • Act as a strategic partner to Product, Technology, Operations, Legal and Business teams, ensuring that new products, markets, and partnerships are designed with “compliance by design” principles.
  • Contribute to the financial crime strategy for the UAE , aligning it with group standards while tailoring to local regulatory expectations and market realities.
  • Provide structured input into new product approval processes , including risk assessments, control proposals, and go-live readiness reviews.
  • Champion a data-driven approach , using metrics, dashboards, and thematic analysis to challenge and improve the financial crime framework.


Training, Culture & Leadership

  • Support the MLRO in delivering AML/CTF training and awareness programmes across the UAE organisation, including tailored sessions for front-line teams, senior management, and specialist functions.
  • Help embed a strong culture of compliance and personal accountability , where financial crime risk is understood and owned by the business.
  • Mentor and develop more junior members of the compliance and financial crime team, acting as a visible, accessible senior point of guidance.


Assurance, Testing & Audit

  • Work with internal audit, compliance testing and external advisors to scope, coordinate and respond to reviews of the AML/CTF framework.
  • Track and drive remediation of findings, recommendations and action plans , ensuring sustainable fixes and timely closure.
  • Periodically perform or oversee thematic reviews (e.g. KYC quality, EDD completeness, TM alert handling, sanctions controls) to identify weaknesses and areas for enhancement.


Candidate Profile

  • 10+ years’ experience in AML / financial crime, with significant time spent in crypto / digital assets, digital payments, or FinTech , or in a leading bank with exposure to high-velocity transactional products.
  • Strong understanding of the UAE regulatory landscape for AML/CTF and virtual assets (e.g. CBUAE, VARA, DFSA, FSRA frameworks), and comfort engaging directly with regulators.
  • Proven experience in designing, implementing and enhancing AML frameworks in complex, technology-driven environments.
  • Familiarity with blockchain analytics tools , transaction monitoring systems, sanctions screening platforms, and related regtech solutions.
  • Demonstrable track record acting as a trusted adviser to senior management , able to balance regulatory expectations with commercial pragmatism.
  • Strong written and verbal communication skills; able to produce clear, concise, regulator-ready documentation and reporting .
  • Professional qualifications such as CAMS, ICA, ACAMS, or equivalent are highly desirable.

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