Money Laundering Reporting Officer, Transak

• 8+ years in financial crime compliance, with meaningful time in an FCA-regulated firm
• Prior service as MLRO, deputy MLRO or nominated officer, with personal SAR and DAML decision-making experience
• Fluent working knowledge of the Money Laundering Regulations 2017, POCA 2002, the Terrorism Act 2000, JMLSG guidance and the FCA Financial Crime Guide
• Direct ownership of a business-wide risk assessment, a transaction monitoring framework, or a sanctions programme
• Demonstrable regulator-facing experience, whether supervisory correspondence, information requests, or inspection
• Capability and appetite to drive a licence application and be its external face, including fronting the firm's financial crime position directly with the regulator
• Fit and proper, with no matter that would obstruct approval as a senior manager function holder

Desirable

• The UK MLRO is Transak's named nominated officer for the UK regulated entity, holding personal statutory accountability under the Money Laundering Regulations 2017 and the Proceeds of Crime Act 2002 for the detection, prevention and reporting of financial crime
• This is a role with individual regulatory liability, not a delegated function. The postholder owns the UK financial crime control environment end to end: risk assessment, policy, customer due diligence, transaction monitoring, sanctions, Travel Rule, suspicious activity reporting, and the relationship with the FCA and the NCA
• The timing is deliberate. Transak is preparing its application through the FCA cryptoasset authorisation gateway, which opens on 30 September 2026 and closes on 28 February 2027
• The UK MLRO is on the critical path for that application and will be expected to drive it, front it, and carry the firm through submission, supervisory scrutiny, and into the FSMA regime that follows
• The successful candidate must be capable of holding the line. The role exists to protect the firm and the market, and that means being willing to say no, to document why, and to defend that position to a regulator
• Statutory Accountability and Nominated Officer Function:
• Act as the named nominated officer under regulation 21(3) of the Money Laundering Regulations 2017 for the UK entity, with personal accountability for the receipt, evaluation and onward reporting of internal suspicion reports
• Own suspicious activity reporting to the National Crime Agency, including SAR quality, DAML requests, consent decisioning, and the management of tipping-off risk under sections 330 to 333A POCA 2002
• Maintain unrestricted and direct access to the Board, with the standing and independence to escalate without filtering through commercial reporting lines
• Hold and evidence continuing fitness and propriety, including readiness to be assessed as the named senior manager function holder on FSMA authorisation
• Ensure the nominated officer function is covered at all times, including through a designated deputy arrangement with documented delegation and handover
• Financial Crime Framework Ownership:
• Own the UK business-wide risk assessment, ensuring methodology, data inputs and conclusions are current, defensible, and connected to actual control decisions rather than produced as a compliance artefact
• Own the AML and CTF policy suite and supporting procedures for the UK entity, ensuring they reflect the Money Laundering Regulations, JMLSG guidance, and the FCA Financial Crime Guide
• Govern the customer due diligence framework, including simplified and enhanced due diligence triggers, PEP and sanctions handling, source of funds and source of wealth standards, and ongoing monitoring
• Own transaction monitoring rule design, calibration and governance, working with Risk Engineering and Data to ensure coverage of relevant typologies, evidenced tuning, and documented rationale for every live rule
• Ensure the control framework is evidenced to a standard that survives supervisory inspection, with clear ownership, testing, and audit trail
• Sanctions, Travel Rule and Crypto-Specific Obligations:
• Own the UK sanctions compliance framework, including screening scope, list coverage, fuzzy matching thresholds, alert handling, true match escalation, and OFSI reporting obligations
• Own Travel Rule compliance under the Money Laundering Regulations, including originator and beneficiary data handling, counterparty VASP due diligence, missing and incomplete data workflows, and sunrise-period risk decisions
• Govern blockchain analytics and wallet screening, including exposure thresholds, indirect exposure treatment, and the escalation path from a screening hit to a freeze or SAR
• Assess and challenge new assets, chains, payment methods and jurisdictions before enablement, applying documented financial crime criteria rather than reacting after launch
• Maintain readiness for asset freeze and reporting events, with a tested playbook covering freeze, restriction, OFSI notification, SAR filing and internal escalation
• Regulatory Engagement and Authorisation:
• Serve as a primary regulatory point of contact for the FCA on financial crime matters for the UK entity, including supervisory correspondence, information requests, and on-site engagement
• Drive the FCA cryptoasset authorisation application and act as its external face on financial crime, owning the financial crime content of the application pack, fronting it with the FCA, and defending it under supervisory challenge through to determination
• Own regulatory reporting obligations, including REP-CRIM and any successor returns, ensuring data accuracy and internal validation before submission
• Translate regulatory change into operational control change, maintaining a horizon-scanning process that produces decisions rather than summaries
• Build credibility-based relationships with supervisors, characterised by early disclosure, accurate reporting, and no surprises
• Governance, Reporting and Assurance:
• Produce the MLRO Annual Report to a standard suitable for Board approval and regulatory disclosure, including honest assessment of control weaknesses and resource adequacy
• Chair or co-own the AML and CFT Committee for the UK entity, ensuring decisions are minuted, actions are tracked, and escalations are resolved
• Provide regular financial crime management information to the Board and Group Leadership, using metrics that show control effectiveness rather than activity volume
• Own remediation delivery for financial crime findings from supervisory assessments, internal audit, and independent review, with evidenced closure
• Support independent testing and assurance of the AML framework, including scoping, response to findings, and challenge where findings are wrong
• Advisory, Leadership and Culture:
• Advise the business on financial crime risk in product, partnership and market expansion decisions, providing a clear position and a documented rationale within agreed service levels
• Lead and develop UK financial crime staff, including the deputy nominated officer and analyst capability, building decision-making capability rather than escalation dependency
• Deliver targeted financial crime training to first line, customer support, sales and engineering, calibrated to the actual risks those functions encounter
• Champion a speak-up culture on financial crime, ensuring concerns surface early and are handled without retaliation
• Act as a visible and credible authority whose challenge is respected commercially, not routed around