Money Laundering Reporting Officer

Money Laundering Reporting Officer (MLRO) - Proficiency in Arabic

Department: Legal, Compliance & Governance

Reporting to: General Counsel / Board of Directors (through Audit Committee as appropriate)

Role Purpose

The MLRO will be responsible for overseeing IMKAN’s Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) framework in compliance with the ADGM FSRA AML Rulebook , UAE Federal AML laws, and other applicable regulations. The MLRO acts as the primary contact point with the FSRA (Financial Services Regulatory Authority) and the UAE Financial Intelligence Unit (FIU) , ensuring timely reporting of suspicious activities and promoting a culture of compliance across the organization.

Key Responsibilities

Regulatory & Statutory Compliance

1. Ensure full compliance with ADGM AML Rulebook , FSRA Guidance, and UAE AML/CTF legislation.
2. Serve as the appointed MLRO registered with ADGM FSRA.
3. Act as the point of contact with FSRA, ADGM Registration Authority, UAE FIU , and other regulators.

AML/CTF Oversight

1. Develop, implement, and maintain IMKAN’s AML/CTF policies, procedures, and internal controls.
2. Conduct risk assessments on customers, transactions, projects, and counterparties.
3. Oversee Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) , and Ongoing Monitoring processes.
4. Ensure screening for sanctions, PEPs (Politically Exposed Persons), and adverse media.

Suspicious Transaction Reporting (STR/SAR)

1. Receive, investigate, and assess internal suspicious activity reports.
2. File Suspicious Activity Reports (SARs) to the UAE FIU in accordance with legal deadlines.
3. Maintain detailed records of SAR decisions, justifications, and communications.

Training & Awareness

1. Develop and deliver AML/CTF training programs for employees and management.
2. Promote a strong compliance culture within IMKAN, ensuring staff understand their obligations.

Governance & Reporting

1. Report regularly to the Board of Directors / Audit Committee on AML/CTF risks, issues, and regulatory updates.
2. Provide Management Information (MI) reports covering AML metrics, risk exposure, and remedial actions.
3. Liaise with Internal Audit and external consultants on AML reviews and inspections.

Investigations & Record-Keeping

1. Lead internal AML/CTF investigations and coordinate with legal, compliance, and risk functions.
2. Ensure proper documentation and secure retention of AML/CTF-related records in line with ADGM requirements.

Qualifications & Experience

1. Education: Bachelor’s degree in Law, Finance, Business, or related field (Master’s preferred) from a well recognised university.
2. Certifications: Recognized AML qualifications (e.g., CAMS, ICA Diploma in AML, or equivalent ).
3. Experience:

• Minimum 5–7 years’ experience in compliance, financial crime, or AML/CTF, preferably within ADGM, DIFC, or UAE-regulated entities.
• Proven experience liaising with regulators and FIUs.
• Experience in real estate, financial services, or DNFBPs (Designated Non-Financial Businesses and Professions) highly desirable.

1. Knowledge: Strong knowledge of ADGM AML Rulebook, UAE AML Laws, FATF Recommendations , and international best practices.
2. Skills:

• Strong analytical and investigative skills.
• Excellent report writing and communication abilities.
• High integrity, independence, and professional judgment.
• Ability to manage cross-functional compliance initiatives.
• Arabic and English proficiency.
• Proficiency in Microsoft or similar software applications

Authority & Independence

1. The MLRO/Deputy shall have independent authority , access to all information necessary to perform AML duties, and direct access to the Board/Audit Committee.
2. Decisions regarding SAR filings shall be made independently by the MLRO in line with legal obligations.

Key Relationships

1. Internal: Executive Committee, Audit Committee, Legal, Finance, Sales, Development, Customer Care.
2. External: FSRA, ADGM RA, UAE FIU, external auditors, legal advisors, and consultants.

Performance Indicators (KPIs)

1. Compliance with regulatory deadlines (SAR/STR filing).
2. Successful completion of internal and external AML audits with minimal findings.
3. Effective delivery of AML/CTF training across IMKAN.
4. Maintenance of an up-to-date AML/CTF risk assessment.
5. Zero regulatory fines or enforcement actions.