Head of Compliance / MLRO

Key Responsibilities Operate independently of business units, with direct and unrestricted access to the Board of Directors and/or Audit Committee in all AML/CFT-related matters. Develop, implement, and maintain comprehensive Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) policies, procedures, and internal controls in accordance with applicable laws, CBB directives, and international best practices. Serve as the primary point of contact with the Central Bank of Bahrain (CBB), the Financial Intelligence Directorate (FID), and other competent authorities on all AML/CFT matters, including the reporting of suspicious transactions and responding to regulatory queries. File Suspicious Transaction Reports (STRs) with the FID and the CBB Compliance Directorate in a timely and accurate manner and prepare periodic AML/CFT reports for the Board, evaluating the adequacy and effectiveness of AML controls. Design, deliver, and document an annual AML/CFT training program tailored to the roles and responsibilities of staff, including senior management. Maintain a formal log of attendance and periodically assess the program’s effectiveness. Ensure the implementation of a Risk-Based Approach (RBA) to AML/CFT, including the development of customer risk profiles, identification of high-risk relationships, application of enhanced due diligence (EDD), and ongoing review of risks. Oversee the effectiveness of the transaction monitoring system, whether manual or automated. This includes defining red flag indicators, setting appropriate alert thresholds, reviewing alerts, and ensuring timely investigation, escalation, and closure. Ensure full compliance with record-keeping obligations under CBB regulations, including the retention of Customer Due Diligence (CDD) files, STR filings, transaction history, and employee AML training records. Conduct continuous customer monitoring, including periodic reviews of high-risk customers, and ensure accurate and complete documentation for CDD, onboarding, and transactional behavior assessments. Draft, maintain, and update the AML/CFT manual in accordance with evolving CBB requirements, group policies (if applicable), and legislative changes. Submit amendments to the regulator as required. Oversee the company’s customer identification program, ensure adherence to KYC procedures, and confirm that record retention policies align with regulatory timelines and standards. Provide AML/CFT-related input in the launch of new products, services, and customer categories, ensuring that money laundering risks are appropriately mitigated from the outset. Ensuring that the company complies with the AML Law and any other applicable AML/CFT legislation and FC Module, Volume 5, the CBB Rulebook. Ensuring day-to-day compliance with Company’s own internal AML/CFT policies and procedures Acting as the company’s main point of contact in respect of handling internal suspicious transactions reports from the company’s staff. Producing annual reports on the effectiveness of the company’s AML / CFT controls, for consideration by senior management in line with FC Module, Volume 5, the CBB Rulebook. Ensure enterprise-wide adherence to the CBB Rulebook, Volume 5 (Specialized Licensees), and other applicable regulations. Lead the development and maintenance of the Enterprise-Wide Risk Management Framework. Oversee the implementation of a risk-based approach across all business activities. Advising and assisting senior management/head of function to identify and assess the main compliance risks facing the company and the plans to manage them. Advising senior management/head of function on compliance with laws, rules and standards, including keeping them informed on developments in the area. Assisting senior management/head of function in educating staff on compliance issues and acting as a contact point within the company for compliance queries from staff members. Establishing written guidance to staff on the appropriate implementation of compliance with laws, rules and standards through policies and procedures and other documents such as compliance manuals, internal codes of conduct and practice guidelines. On a pro-active basis, identifying, documenting and assessing the compliance risks associated with the company’s business activities, including the development of new products and business practices, the proposed establishment of new types of business or customer relationships, or material changes in the nature of such relationships. Monitoring and testing compliance by performing sufficient and representative compliance testing. Reporting on a regular basis to the board of directors or the Audit committee of the board of directors. Requirements Bachelor's degree in Law, Finance, Business, or a related field 10+ years of experience in compliance and/or financial crime roles, with meaningful experience in payments, e-money, fintech, or financial services Strong knowledge of the Bahrain regulatory environment and relevant regulatory requirements Demonstrated experience as, or readiness to be approved as, a Compliance Officer and/or MLRO Strong understanding of AML/CTF frameworks, KYC/KYB, sanctions, and transaction monitoring Experience developing and implementing compliance policies, frameworks, and controls Strong understanding of risk management, regulatory reporting, and compliance monitoring Professional certification such as ICA, CAMS/ACAMS, or equivalent is preferred Comfortable operating hands-on in an early-stage, fast-moving environment Strong analytical, problem-solving, and decision-making skills Strong written and verbal communication skills in English and Arabic High level of ownership, attention to detail, and integrity Able to work effectively with senior stakeholders, management, and cross-functional teams Show more Show less