About Transak:
Transak is a leading Web3 onboarding infrastructure provider. Its API-driven solutions enable Web3 platforms to onboard users from 170+ countries to crypto while abstracting the complexity of user KYC, risk monitoring & compliance, payment methods and customer support. Transak is a product of the Tachyon accelerator program and is backed by top VCs including Consensys and Animoca Brands. We are a team driven by innovation, committed to pioneering seamless digital solutions in the web3 and crypto space.
Job Overview:
The Deputy MLRO’s role is to support the appointed MLRO with overseeing the anti-money laundering (AML) efforts of Transak GmbH by reporting suspicious activities to regulatory authorities, ensuring compliance with AML regulations, overseeing AML/CTF practices and processes, implementing and overseeing the adoption of adequate policies and practices by the local team, ensuring employees receive AML/CTF training and managing the internal AML strategy. This includes receiving and reviewing internal reports, filing suspicious activity reports (SARs) with the A-FIU and cooperating with external audits and investigations.
Key Responsibilities:
- Act as the secondary point of contact inside the obliged entity responsible for anti-money-laundering (AML) matters and for liaison with the FIU and supervisory authorities (FMA, OeNB).
- Manage the internal reporting channel (receive staff reports of suspicions), promptly assess those reports and decide whether they constitute grounds for an external suspicious transaction/ activity report (SAR) to the FIU and submit SARs to the FIU and maintain open and transparent communication with all relevant authorities and take the legally mandated measures to not execute, to suspend, or to delay transactions in accordance with the FM-GwG rules and FIU instructions.
- Review adequacy of AML policies, procedures and internal controls (CDD, EDD, transaction monitoring, sanctions screening, travel-rule procedures, etc.) and that these are implemented and kept up to date.
- Assists with the performance and documentation of periodic AML/CTF/PF risk assessments and that risk-based measures (CDD/EDD/monitoring) flow from those assessments of Transak GmbH.
- Oversees AML training for staff, ensuring employees know how to detect and report suspicious activity and understand their duties; keep training records.
- Reviews retention of AML records (CDD documents, transaction records, SARs, risk assessments, policies and training records) in the legally required format and for the legally required retention period.
- Monitors whether sanctions screening and related procedures are integrated into the AML control framework and escalate/handle any sanctions hits in accordance with legal reporting and freezing obligations.
- Reviews transaction monitoring rules, case management and the risk-scoring logic including their maintenance, validation and investigation of alerts is done in a documented and timely manner.
- Issue compliance opinions as mandated by the existing policies and processes in respect of products, expansion and development efforts, and all matters raised internally by relevant stakeholders.
- Act as a point of advisory for all employees and senior management on all matters related to regulatory compliance and preparation for implementation of legal and regulatory provisions entering into force in the short, medium and long term.
- Participates in internal investigations of reported wrongdoing whether via whistleblowing or usual reports and present the findings to the board and relevant stakeholders.
- Periodically report to the MLRO and local board AML & Compliance matters in accordance with the provisions of internal governance arrangements.
Qualifications:
- Advanced knowledge of AML, CTF, PF regulations and practices;
- At least 5 to 7 years of experience in compliance, AML/CTF;
- Knowledge of local and international regulations and the ability to apply this knowledge appropriately;
- Awareness of the risks and the responsibilities related to financial transactions and potential money laundering cases;
- Demonstrated record of keeping up to date with AML/CTF regulations and practices (CPE or equivalent);
- Understanding of how AML regulations apply to financial institutions and the crypto industry in Austria and the EU
- Confidence to act independently and make final decisions;
- AML and crypto compliance qualifications/certifications - ICA/ACAMS.
Conflicts of Interests arrangements (if applicable):
The Deputy MLRO will act as an alternate decision point to ensure adequate mitigation of conflicts of interest and that the 4 eyes principle is respected at all times:
- Where an investigation is conducted by the MLRO, the deputy MLRO will be responsible for the final decision on the matter and a recommendation on course of action/next steps.
- Where a recommendation is made by the MLRO, the Deputy MLRO will review the case and will have final decision power over the respective matter.
- Where an issue is raised for investigation against the MLRO, the Deputy MLRO will conduct the respective investigation and will report their findings with the Group Compliance Officer.