Job Title:                     (Position Filled) Head of AML/KYC

Salary:                        £45K - £60K

Location:                    London


Job Purpose

  • Manage the Customer Verification team, and playing a leading role in the creation, implementation and delivery of policy to ensure that (AML), (CTF), (KYC) and Sanctions regulatory requirements are met at the on-boarding stage of new relationships and then continued during in-life management of relationships.

  • Act as the AML and financial crime lead ensuring that all areas of the business are compliant with relevant law and regulation.

  • To engage with staff across the business to ensure they have the skills and knowledge to best protect the business and its customers.

  • To engage with members (as required) to advocate for the policies and procedures adopted to secure compliance.

Key Responsibilities

Policies and procedures

  • Working with the Compliance Director to the creation and implementation of AML, KYC & Sanction rules including those relating to (PEPs)

  • Developing and delivering the financial crime policies and procedures to enable its compliance with regulatory requirements

  • Maintaining processes and procedures for EDD for high risk customers, as agreed with management and the MLRO and ensuring that a clear audit trail is maintained

  • Ensuring that AML, CTF, KYC & Sanctions related policies and procedures are complete, fit for purpose and reviewed annually in liaison with the MLRO


  • Working with and advising the compliance director on AML activities, with recommendations or otherwise on the AML status of active customers

  • AML, KYC, CTF, PEP and Sanctions subject matter expert for the business and providing sign off to Customer Risk Assessments (CRA) drafted by the KYC team

  • Ensuring that clear and verified information on application ownership structures, including ultimate beneficial ownership, source of wealth are available and retained for audit & regulatory review purposes

  • Providing AML, KYC, CTF & Sanctions expertise to review new and amended regulation and legislation, to help highlight and implement requirements for the business.

  • Conducting gap analyses and making appropriate recommendation to remediate against AML, KYC, CTF & Sanctions regulatory requirements

  • Ensuring that financial crime intelligence is shared between all parts of the business

  • Liaising with and observing the requirements of the MLRO and supporting team in respect of all AML CDD, PEP and sanctions issues and requirements

  • Overseeing the hotline, to provide operational staff with support (on an exceptional basis) out of hours


  • Developing the KYC team’s investigation skills and AML knowledge where appropriate

  • Preparing and presenting material for staff training and communications in liaison with the MLRO

  • Ensuring that all staff complete regular AML refresher training and that specific staff with higher level needs receive appropriate training


  • Preparing all required reports, documentation and accurate management information for the Executive Board and Compliance Committee Meetings on AML, KYC, SARs & Sanctions related management information and reporting

  • Contributing to preparation of the MLRO annual report

Ongoing Monitoring

  • Undertaking daily checks of the KYC team’s work to ensure that decisions are of a consistently high quality and that any remedial actions required are identified and implemented in a timely manner

  • Monitoring and policing completion of all CDD/EDD requirements on approved cases with related conditions precedent

  • Ensuring that on-going alerts such as adverse media, PEP and sanctions hits and persons of special interest are reviewed on a timely basis and appropriate action taken

  • Maintaining, monitoring and executing periodic reviews to ensure that AML policies and controls are being observed

  • Reviewing business performance against SLAs, reporting non-compliance and devising and executing corrective action


  • Leading the business with all AML, KYC, CTF & Sanctions related enquiries, including advising on the requirements of the appropriate regulatory regimes and resolving case related enquiries

  • Assisting with internal investigations in relation to SARs and implementing the AML compliance frameworks

Line Management

  • Manage the KYC team, ensuring all tasks, duties and responsibilities are handled in a timely, professional, accurate manner and consistently high quality manner

  • Continuous development for less experienced members of the team on financial crime and keeping oversight of the investigations and reviewing the worked cases

Risk Management

  • Using AML knowledge and experience to ensure the business is better protected from customers using the proceeds of crime

  • Liaison with staff across the business on AML, KYC, CTF and Sanctions related matters and establishing close working relationship with the KYC team

  • Building and maintaining strong relationships across the sector with external partners

  • Providing the business and its senior management with guidance and advice related to financial crime regulatory requirements

  • Using a risk based approach to review the AML and general Financial Crime risk landscape, governance and controls framework and report on and implement improvements with the agreement of the MLRO

  • Delivering the clearance of audit, operational risk and compliance related AML, KYC, CTF & Sanctions issues

  • Maintaining appropriate contacts at peer organisations through attendance at industry events

  • Horizon scanning for changes in regulation and legislation which will have an impact on business operations

  • Facilitating review and update of risk appetite in respect of AML, KYC, CTF & Sanctions


  • A minimum of 5 years’ experience in a compliance/financial investigatory role

  • Detailed knowledge of the UK AML, KYC, CTF & Sanctions (and where applicable, overseas) regulatory regime and requirements

  • Knowledge of SAR’s and law enforcement requirements

  • Experience of dealing with and identifying money laundering techniques and its associated crimes

  • Experience of undertaking and leading financial crime investigations

  • Enhanced knowledge of AML, CTF and Tax evasion

  • Knowledge of overseas AML high risk and non-equivalent countries and territories

  • Practical knowledge and experience of commonly deployed anti money laundering systems

  • Knowledge and experience of drafting AML, KYC, CTF & Sanctions policies and procedures

  • Knowledge and experience of analysing information provided in support of CRAs and providing approval of such


  • AML Investigator (completed or in progress) desirable.

  • Financial intelligence officer or similar (completed or in progress) desirable.

  • PML (from the Gambling Commission) holder desirable

Key competencies:

  • Excellent written and oral communication skills

  • Confident interacting with staff at all levels of the business up to senior management level and providing appropriate level of constructive challenge to information provided for assessment

  • Able to advocate for the AML/KYC risk approach adopted when dealing with members

  • Excellent data analysis skills

  • Ability to prioritise tasks, deliver to a consistently high standard while managing competing deadlines, proactive problem solver

  • Customer focused and risk aware


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