Job Purpose:
To lead the transaction monitoring team in the detection and analysis of potentially suspicious transactions through systematic review of alerts, supporting the AML program’s effectiveness and regulatory compliance.
Key Responsibilities:
1. Transaction Monitoring & Investigation
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Review and investigate alerts generated through AML monitoring systems in line with CBUAE, VARA, and SCA regulation and guidance.
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Leverage risk-based approach as per CBUAE guidelines for prioritizing alerts and ongoing monitoring.
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Apply enhanced due diligence (EDD) for high-risk scenarios, including cases involving PEPs, virtual asset transactions, or cross-border activity as emphasized by VARA and SCA.
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Identify and investigate typologies highlighted by UAE regulators, such as: structuring (“smurfing”), Trade-based money laundering, Use of virtual assets in layering or obfuscation, Use of shell companies/funnel accounts etc.
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Ensure adherence to timeline requirements for reviewing and escalating alerts as specified by CBUAE (often 20 business days for STR/SAR).
2. Suspicious Transaction/Activity Reporting (STR/SAR)
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Prepare and submit STRs/SARs in strict compliance with CBUAE, VARA, and SCA regulations, including full and accurate narrative, supporting evidence, and adherence to prescribed reporting channels (e.g., goAML).
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Support the ongoing development and calibration of detection scenarios in accordance with changes in regulatory expectation or emerging typologies notified by authorities.
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Maintain comprehensive records of all investigated alerts and reported cases for the minimum prescribed period (typically 5+ years, per UAE regulations).
3. Governance, Policies, and Training
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Ensure AML/CTF policies and procedures are up-to-date with CBUAE, VARA, and SCA rules and regulatory updates.
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Deliver periodic training programs to the first line of defense on new regulations (including virtual asset compliance obligations), typologies, and best practices.
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Participate in regulatory thematic reviews or inspections, providing records and support as required.
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Perform gap analysis and contribute to regular FCC policy reviews to ensure alignment with new regulatory guidance or enforcement trends.
4. Risk Assessment and Ongoing Controls
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Support the FCC unit in periodic ML/TF risk assessments as required by all three regulators.
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Utilize internal and external data to inform KYC refresh requirements according to entity and activity risk ranking (banking, securities, or virtual assets).
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Assist with implementing recommendations from regulatory inspection findings or internal/external audit reports.
5. Confidentiality & Recordkeeping
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Maintain strict confidentiality in all investigations, with particular sensitivity to specific UAE privacy/data protection mandates.
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Assure all records (alerts, investigations, training logs, reports) are available for regulator or audit review.
6. Other Regulatory Obligations
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Promptly report any attempted regulatory breaches, sanctions, or suspicious customer behavior to the MLRO/CO in accordance with local law.
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Ensure compliance with CBUAE, VARA, and SCA’s requirements for escalation, including immediate reporting of critical matters (e.g., threshold triggers for virtual assets per VARA).
Key Skills, Qualifications & Experience:
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Bachelor’s degree in Finance, Business Administration, Law, Accounting, Economics, or a related field. Master’s degree is an advantage.
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Certification in Anti-Money Laundering or Financial Crime Compliance (e.g., CAMS, ICA, CFE, CFCS).
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Additional certifications related to virtual assets or securities compliance (such as a VARA-recognized program) are advantageous.
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Minimum 7–10 years of relevant experience in AML, compliance, or financial crime investigation.
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Demonstrated track record leading AML monitoring teams in a banking, securities, or virtual asset environment.
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Experience in direct dealings with regulators (CBUAE, VARA, SCA) is preferred.
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Proficiency in transaction monitoring systems, KYC platforms, STR/SAR preparation (incl. goAML), and regulatory reporting.
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Skills in financial crime investigation, data analysis, and delivering training while ensuring confidentiality of sensitive case data.