Director, Compliance, AMLCO

Director, Compliance, AMLCO – Sydney, Australia

​​ T he Director, AML Compliance, AMLCO (otherwise known as Money Laundering Reporting Officer or MLRO) serves as WUFSA's formally appointed Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Compliance Officer as mandated by and defined under the Australian AML/CTF regulatory framework.

The role is responsible for leading the Australian AML/CTF compliance function, overseeing and coordinating the implementation and ongoing effectiveness of WUFSA's AML/CTF Program, ensuring compliance with applicable AML/CTF legislative and regulatory requirements, and supporting the identification, assessment, monitoring and management of money laundering, terrorism financing, proliferation financing, sanctions and other financial crime risks across the business.

​The role provides strategic oversight, leadership and subject matter expertise of AML/CTF governance, risk assessment, monitoring, controls, training and regulatory compliance activities. The role is responsible for ensuring AML/CTF risk considerations are embedded into business decision-making, new products, services, delivery channels and strategic initiatives. The incumbent also provides independent challenge and oversight to ensure financial crime risks are appropriately identified, assessed, managed and escalated across the organisation.

​While primarily focused on the Australian AML/CTF regulatory framework, the role is expected to lead regional AML/CTF projects across APAC, providing subject matter expertise, guidance and coaching to AML/CTF Compliance Officers and MLROs across the region.

​ Role Responsibilities

REGULATORY APPOINTMENT REQUIREMENTS:

This position is the designated AML/CTF Compliance Officer for WUFSA.

The AML/CTF Compliance Officer has direct access to the WUFSA Governing Body and may escalate material AML/CTF matters independently of operational management where required to fulfil regulatory obligations. The role is responsible for maintaining an effective AML/CTF governance framework and ensuring AML/CTF obligations are communicated, implemented and monitored across the organisation.

The position holder shall:

Serve as the nominated AML/CTF Compliance Officer for WUFSA.

Act as primary contact with AUSTRAC regarding AML/CTF matters.

Oversee and coordinate day-to-day compliance with AML/CTF legislation (comprises the Act, Rules and other applicable regulatory guidance and requirements), applicable sanctions obligations; WUFSA AML/CTF Program and WU global AML/CTF standards.

Oversee the effectiveness of AML/CTF governance, risk management, and compliance controls.

Escalate material AML/CTF risks, breaches and deficiencies to Senior Management and the Governing Body.

Provide periodic AML/CTF reporting to Senior Management and relevant governance forums.

Formally report AML/CTF compliance outcomes and program effectiveness to the Governing Body at least annually.

Maintain eligibility to perform the role throughout tenure.

Meet all competency, authority, and independence, and fit-and-proper requirements established under WUFSA's AML/CTF Program and associated governance framework.

AML/CTF Program Governance and Oversight

• •Own and oversee the WUFSA AML/CTF Program.
• •Maintain AML/CTF policies, procedures, controls and governance documentation.
• •Ensure AML/CTF frameworks remain aligned with legislative requirements and regulatory expectations.
• •Oversee implementation of AML/CTF controls across all designated services.
• •Ensure AML/CTF documentation remains fit for purpose and current.
• •Coordinate periodic reviews and updates of the AML/CTF Program.

Oversee remediation of compliance deficiencies, audit findings and regulatory issues.

AML/CTF Compliance Officer and MLRO Responsibilities

• •Perform statutory responsibilities of the AML/CTF Compliance Officer.
• •Act as the principal AML/CTF contact with AUSTRAC.
• •Ensure compliance with all AML/CTF reporting obligations, including Suspicious Matter Reports (SMRs), Threshold Transaction Reports (TTRs), International Funds Transfer Instructions (IFTIs) and other regulatory reporting requirements.
• •Oversee suspicious activity investigations, decision-making and escalation processes.
• •Oversee the effectiveness of Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) and ongoing customer monitoring controls.
• •Ensure AML/CTF risk considerations are incorporated into new products, services, systems, delivery channels and material business change initiatives.
• •Oversee sanctions compliance controls and escalation of potential sanctions-related matters.
• •Ensure AML/CTF record-keeping obligations are maintained and periodically tested.
• •Oversee implementation and monitoring of remediation programs arising from audits, compliance reviews, regulatory examinations and issue management activities.
• •Maintain regulatory documentation, appointment records and compliance evidence.
• •Support regulatory examinations, inspections, enquiries and information requests.
• •Maintain awareness of emerging financial crime typologies, regulatory developments, sanctions risks and industry best practices.

Ensure the organisation's AML/CTF obligations are effectively communicated and understood across relevant business areas.

Financial Crime Risk Management

• •Oversee the effective design and execution of enterprise AML/CTF risk assessments including associated customer, product, channel and geographic risk assessments.
• •Ensure effective management of financial crime risks including money laundering, terrorism financing, proliferation financing, sanctions, and fraud, based on risk assessment outcomes and controls being implemented to manage the identified risks.
• •Ensure enhanced due diligence requirements are effectively implemented.
• •Review and appropriately challenge other business risk assessments as required.

Escalate material financial crime risks to senior management and governance forums.

Governance, Board Reporting and Regulatory Engagement

• •Prepare periodic AML/CTF compliance reporting for Senior Management, Governing Body and other governance forums. Retain ownership and control of AML/CTF Compliance Officer reports and recommendations provided to the Governing Body, ensuring material findings, risks and recommendations are communicated transparently and without inappropriate modification.
• •Provide formal AML/CTF Compliance Officer reporting to the Governing Body at least annually, including:

· Compliance with AML/CTF policies and procedures;

· Effectiveness of AML/CTF controls in managing ML/TF risks;

· Compliance with AML/CTF legislative and regulatory obligations;

· Material AML/CTF deficiencies, breaches and remediation activities.

• •Escalate material AML/CTF incidents, compliance breaches, significant control deficiencies, emerging regulatory concerns and material financial crime risks as required.
• •Present significant compliance issues, regulatory developments, financial crime trends, breaches and emerging risks to governance forums and senior stakeholders.
• •Oversee responses to internal / external audit, compliance review, independent evaluation and regulatory findings.
• •Monitor closure of audit, regulatory and review findings and ensure timely remediation of identified issues.
• •Maintain effective relationships with regulators, governance stakeholders and relevant internal control functions.
• •Provide strategic advice and independent challenge to support informed decision-making regarding AML/CTF and financial crime risk matters.

Ensure Senior Management and the Governing Body remain informed of the effectiveness of the AML/CTF Program and material financial crime risks.

Monitoring, Training and Program Enhancement

• •Oversee AML/CTF compliance monitoring activities.
• •Ensure AML/CTF training programs remain effective, current and risk based.
• •Promote and maintain a strong financial