Regulatory Compliance Officer

Overview

I. Governance, Strategy & Risk Management

• **AML/CFT Program Ownership:**
• Develop, implement, manage, and continuously update the comprehensive AML/CFT program, policies, and procedures, ensuring specific controls for
• Virtual Asset transfers, wallet management, and cross-chain transactions.
• **Risk Assessment:**
• Conduct and periodically refresh the firm’s comprehensive Institutional Risk Assessment (IRA), specifically identifying, measuring, and mitigating Money Laundering (ML) and Terrorist Financing (TF) risks associated with
• new virtual asset listings, decentralised protocols, and emerging financial crime typologies.
• **Senior Management Reporting:**
• Prepare and submit semi-annual MLRO reports to the Board/Senior Management, detailing the efficacy of the AML/CFT program, identifying deficiencies, and recommending clear remediation steps with deadlines.
• **Regulatory Adherence**
• : Create policies and procedures that align with business activities and regulatory expectations.

II. Regulatory & Reporting Obligations

• **Financial Intelligence Unit (FIU) Liaison:**
• Serve as the designated point of contact for the UAE FIU, mandatory registration and utilization of the
• goAML platform
• for all required reporting.
• **Suspicious Reporting (VA Focused):**
• Receive, review, scrutinize, and analyze all internal Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) related to Virtual Asset transfers.
• This includes analyzing complex on-chain activity patterns and utilizing external analysis for decision-making.
• **Mandatory Reporting:**
• Oversee the timely submission of all mandatory reports via goAML, including STRs/SARs, Fund Freeze Reports (FFR), Partial Name Match Reports (PNMR), and High-Risk Country Reports (HRC).
• **Regulatory Communication:**
• Handle all communication, inquiries, and requests for information from the Supervisory Authority (e.g., VARA, CBUAE, DFSA, FSRA) and law enforcement agencies concerning
• digital asset investigations.
• **Sanctions Compliance:**
• Ensure immediate compliance with targeted financial sanctions regimes, conducting
• wallet address screening
• and executing
• freezing without delay
• on funds or assets belonging to sanctioned individuals or entities.

III. Operations & Control

• **Virtual Asset Due Diligence (VADD):**
• Oversee the effective implementation of Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) processes, specifically addressing the source of funds/wealth in Virtual Assets and the risk profiling of private wallets and counterparties.
• **Know Your Transaction (KYT) Monitoring:**
• Maintain and optimize the KYT system, utilizing blockchain analytics to monitor transaction flows, flag high-risk clusters (e.g., mixers, darknets, illicit addresses), and ensure alert parameters are effective in detecting unusual activity.
• **Record-Keeping:**
• Ensure all required documentation relating to CDD,
• on-chain investigation logs
• , transactions, compliance monitoring, and reporting is maintained and readily retrievable for the minimum statutory period (currently five years).
• **Training:**
• Design, execute, and document ongoing AML/CFT training that includes specific modules on
• Virtual Asset risk indicators, blockchain analysis tools, and VASP regulatory obligations.

IV. Audit & Review

• **Internal Audit:**
• Coordinate and facilitate independent internal and external audits of the AML/CFT program, ensuring specific scrutiny of Virtual Asset controls and prompt implementation of corrective actions for all deficiencies.

Required Experience

• **5-10 years**
• of progressive experience in AML/CFT compliance, financial crime prevention, or risk management, with at least
• 3 mandatory years within the Virtual Asset industry;
• **Mandatory UAE Experience:**
• Demonstrated experience operating as an MLRO, Head of Compliance, or Deputy MLRO within the UAE in a minimum of two virtual asset supervisory authorities (VARA and ADGM or equivalence);
• Deep practical knowledge of

Federal Decree-Law No. 20 of 2018

• and its Implementing Regulations, FATF Recommendations (specifically Recommendation 15 on VASPs), and relevant local DLT/VA frameworks;
• **Essential Technical Skill:**
• Proven proficiency and hands-on experience using industry-standard
• blockchain analytics tools (e.g., Chainalysis, Elliptic, TRM, etc.)
• for on-chain investigations and risk scoring.

Education And Certification

• Bachelor's degree in Law, Finance, or a related field;
• **Mandatory Certification:**
• Possession of a globally recognized certification, such as

Certified Anti-Money Laundering Specialist (Cams)

Core Competencies

• **Independence & Entrepreneurial mindset:**
• The proven ability to act independently and exercise authority necessary to ensure regulatory compliance, even if contrary to the commercial interests of the firm.
• **Judgment:**
• Exceptional analytical, investigative, and decision-making skills, with the ability to exercise sound judgment in complex
• virtual asset financial crime scenarios.
• **Communication:**
• Fluent English is mandatory; fluency in Arabic is highly beneficial.
• Must possess superior report-writing and presentation skills for communication with the Board and regulators.
• **Leadership:**
• Demonstrated leadership and management capabilities to oversee a compliance team and foster a strong culture of compliance across the organization.