MLRO/Financial Crime Manager

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THE ROLE

The MLRO / Financial Crime Manager is the designated Money Laundering Reporting Officer (MLRO) and Compliance Officer, within the meaning of the UAE AML/CFT Decision and CBUAE Guidelines, and owns the organization's AML/CFT program end-to-end. The role holder is ultimately responsible for ensuring an appropriate AML/CFT program exists, that the organization deploys an effective risk-based approach to detect and report suspicious activity, and for the identification, investigation, and reporting of suspicious activity related to money laundering, terrorist financing, financial crime, and fraud. The role owns the design, tuning, and effectiveness of transaction monitoring and screening for both financial crime and fraud typologies, manages the FinCrime and Fraud team, and acts with independence in decision-making on matters within its remit. The MLRO / Financial Crime Manager is the organization's primary point of contact with the CBUAE, the Financial Intelligence Unit (FIU), and law enforcement agencies on AML/CFT and financial crime matters, and provides Senior Management, the Head of Compliance/CLCO, and the Board with clear, regular reporting on program effectiveness. This role is subject to CBUAE approval as the Company's Money Laundering Reporting Officer.

RESPONSIBILITIES

MLRO Designation and Program Ownership: Act as the designated MLRO in line with Financial Crime Regulations, owning, designing, and continuously enhancing the organization's AML/CFT program, including its governance, policies, procedures, and controls, aligned with UAE law, CBUAE regulations and Guidelines, and international standards.

Detection and Investigation: Detect and monitor transactions relating to money laundering, the financing of terrorism, the financing of illegal organizations, fraud, and other predicate crimes; review and investigate internal SARs/STRs and other flagged transactions or activities, obtaining legal advice as necessary, and documenting findings and next steps.

SAR/STR Decision and Filing: Decide, in full confidentiality, whether to notify the FIU by submitting an STR/SAR or to maintain the transaction, documenting the rationale for that decision, and report suspicious activity to the FIU and relevant regulators in a timely and accurate manner.

Post-Filing Actions: Implement appropriate follow-on actions after an STR, SAR, or other suspicious activity report is filed, including placing the subject on internal watchlists or blacklists for close monitoring, updating the customer's risk rating, and tracking remediation of related control gaps.

AML/CFT Risk Assessment: Lead regular, organization-wide AML/CFT risk assessments to identify and mitigate vulnerabilities to money laundering and terrorist financing, and review all AML/CFT risk matters on an ongoing basis with the Compliance Lead and Risk Officer.

Regulatory and Law Enforcement Liaison: Act as the primary point of contact for the CBUAE, the FIU, and law enforcement agencies on AML/CFT and financial crime matters, including leading responses to law enforcement production orders and other formal requests; cooperate with the Supervisory Authority and the FIU by providing requested data and enabling authorized personnel to access necessary records and documents; and, where possible, share knowledge, report cases, and develop best practices to improve coordination within the financial sector.

Database and Screening Checks: Ensure accurate checking of relevant sanctions, watchlist, and other databases following notices from regulatory authorities or law enforcement, and own the organization's sanctions, watchlist, and politically exposed persons (PEP) screening programs, including escalation and Senior Management approval processes for high-risk relationships.

Register Maintenance: Maintain the Internal, External, Enquiries, and PEP Registers along with supporting team.

Advisory to Head of Compliance: Advise the Head of Compliance on financial crime compliance related matters.

Committee Participation: Participate in the Fraud, Compliance, and Risk Committee(s).

Compliance/MLRO Sign-Off: Review payments and activities that require Compliance/MLRO sign-off.

Policy and Procedure Review: Review internal AML/CFT and financial crime rules and procedures, assess their consistency with relevant laws and regulations, evaluate the organization's level of compliance with them, and propose what is needed to update and develop them.

Independent Assessment: Assess the establishment's level of compliance with AML/CFT and financial crime internal systems and procedures and propose enhancements.

Reporting to the Board and CLCO: Report directly to the Board and escalate relevant issues as needed; prepare and deliver reports to the CLCO; and prepare and submit periodic reports (including semi-annual reports) on the effectiveness of the AML/CFT and financial crime program directly to Senior Management, sending a copy to the relevant Supervisory Authority upon its request, together with Senior Management's observations and decisions.

Training: Monitor the developpment, implementation, and document ongoing training and development programs and plans for employees on money laundering, the financing of terrorism and of illegal organizations, fraud and financial crime, and the means to combat them, and support the Compliance Lead in delivering AML/CFT training to employees.

Transaction Monitoring and Fraud Prevention: Own the design, implementation, continuous optimization, and periodic review of transaction monitoring and screening rules and controls to prevent fraud and detect suspicious financial activity, collaborating with internal stakeholders to strengthen fraud prevention frameworks and enhance monitoring capabilities through data-driven insights and technology-enabled solutions.

Team Management: Manage the performance of, and develop, the FinCrime and Fraud team, driving investigative and escalation processes and ensuring effective oversight of regulatory and compliance reporting activities, including timely submission of reports in line with internal policies and regulatory requirements.

Fitness and Propriety: Support screening procedures to ensure high standards of fitness and propriety in the appointment of employees performing AML/CFT and financial crime functions.

CBUAE Approval and Fit and Proper Status: Maintain CBUAE approval as MLRO, including satisfying ongoing fit-and-proper requirements, and promptly notify the CBUAE of any change in circumstances affecting that approval.

Ongoing Awareness: Maintain awareness of obligations under relevant AML/CFT legislation, CBUAE Guidelines, and industry best practices.

Collaborate closely with the Compliance Lead, Director, Risk Manager, Legal, and other stakeholders to support overall compliance and risk mitigation strategies.

AML/FINANCIAL CRIME TOOLS AND SYSTEMS FAMILIARITY:

Transaction Monitoring Systems (e.g., NICE Actimize, FICO TONBELLER, Oracle Mantas, SAS AML)

Sanctions Screening Tools (e.g., World-Check, Dow Jones