MLRO & Compliance Advisor

Or client, operating within the financial services industry, are seeking to hire a compliance professional to run its AML/CFT and regulatory compliance functions and to advise its service teams. Candidates without a prior MLRO title are welcome if they bring solid compliance advisory and AML experience.

The purpose of the role is to keep the client compliant with the PMLFTR, the FIAU Implementing 
Procedures and its MFSA Class C CSP license conditions, while helping the business take on good clients 
efficiently. It combines three functions: MLRO (AML/CFT and reporting), Compliance Officer (MFSA license obligations) and Compliance Advisor (day-to-day guidance to client-facing teams).

Responsibilities:

Regulatory Liaison and Reporting

• Act as the appointed MLRO and central point of contact with the FIAU and the MFSA.
• Receive and investigate internal suspicion reports, document decisions and submit Suspicious Transaction Reports (STRs) to the FIAU in a timely manner.
• Manage regulatory submissions, including the annual REQ, questionnaires and FIAU requests for information.
• Coordinate regulatory inspections, thematic reviews and external audits, and oversee any resulting remediation.
• Prepare and present quarterly MLRO and Compliance reports and AML/CFT management information for the Board.

Framework and Risk Assessment

• Maintain and update AML/CFT policies, procedures and controls, including periodic gap analyses.
• Oversee and update the Business Risk Assessment, the Customer and Jurisdictional Risk Assessment methodologies, the Risk Appetite Statement and the client risk register.
• Monitor the adequacy and effectiveness of AML/CFT controls and risk management policies and the level of adherence by staff.
• Ensure alignment with the PMLA, PMLFTR, FIAU Implementing Procedures (Parts I and II for CSPs, Accountants & Auditors and Tax Advisors), FATF Recommendations and MFSA expectations.

Due Diligence and Monitoring

• Review and approve CDD and EDD files at onboarding and periodic review, obtaining senior management approval for high-risk and PEP relationships.
• Approve or refuse high-risk clients, and recommend exiting relationships where risk cannot be mitigated.
• Assess source of wealth and source of funds, including through financial statements, contracts and transaction documents.
• Oversee ongoing monitoring, sanctions and PEP screening, adverse-media screening and enhanced oversight of high-risk clients.
• Advise on red flags in client records, unusual transactions and gaps between activity and declared business
• Provide guidance to client-facing teams on AML/CFT requirements.

CSP Compliance

• Ensure ongoing compliance with the Company Service Providers Act, the MFSA CSP Rulebook and the conditions of the clients Class C license.
• Design and run an annual, risk-based Compliance Monitoring Programme, and track findings to closure.
• Maintain the Compliance Manual and related policies: conflicts of interest, outsourcing, record keeping, complaints and breach reporting.
• Monitor directorship and company secretary appointments held by the clients officers, including time commitment, conflicts and the real oversight each role requires.
• Assess and record breaches and incidents, and notify the MFSA where required.
• Carry out due diligence on outsourced service providers and review the related agreements.
• Monitor regulatory developments in Malta and the EU, and assess their impact on the client.

Training and Continuous Improvement

• Deliver AML/CFT training across the organization, maintain training logs and promote a strong compliance culture.
• Monitor regulatory developments, including the EU AML package and AMLA, and update internal frameworks accordingly.
• Oversee Deputy MLRO or Designated Employee cover arrangements.

Requirements:

• Degree in Law, Finance, Accountancy, Business or a related field.
• Professional AML/CFT certification (ICA or ACAMS) is considered an asset.
• At least 5 years in AML/CFT or regulatory compliance in a subject person in Malta, such as a CSP, trustee, accounting or audit firm, bank or financial institution. Being already approved by MFSA as MLRO is an asset but equivalent hands-on AML/CFT and compliance advisory experience is accepted.
• Strong working knowledge of the PMLA, PMLFTR, FIAU Implementing Procedures, EU AML Directives and the CSP Rulebook.
• Experience writing or reviewing AML/CFT policies, risk assessments and Board-level reports.
• Ability to meet the MFSA fitness and properness standard.
• Strong analytical, investigative and written communication skills, particularly in regulatory correspondence.
• Holds firm on AML/CFT decisions under commercial pressure, while explaining them clearly to partners and clients.
• Applies a genuine risk-based approach rather than one rule for every case.
• High integrity, sound judgement, strict confidentiality and the ability to work independently.

Benefits:

• Remuneration package of circa EUR 65,000 per annum, commensurate with experience.
• Two days of remote working per week following the probationary period.
• Private health insurance following the probationary period.
• Dedicated parking space.
• Annual performance reviews.
• Sponsored AML/CFT training and continuous professional development