Manager - Compliance

Our client is a real-time payment services company established under the National Payment System (NPS) Act. They aim to address the challenges of inter-bank money transfers within the country and beyond.

This role involves overseeing regulatory compliance, anti-money laundering (AML), combating the financing of terrorism (CFT), and combating the financing of proliferation (CPF) operations. The manager will also be responsible for transaction surveillance, data protection and privacy governance, and Know Your Customer (KYC) and Know Your Business (KYB) oversight. Key duties include regulatory horizon-scanning, compliance quality assurance, and providing legal and regulatory advisory. The successful candidate will work closely with internal and external partners to ensure robust AML/CFT/CPF, transaction surveillance, data protection, privacy, AI compliance, and KYC/KYB due diligence governance. Additionally, the role supports the operationalization and governance of the business Scheme Council and establishes a compliance quality assurance process across core business operations, while also assisting with legal and regulatory advisory activities.

1. Oversee daily transaction screening and monitoring for Politically Exposed Persons (PEPs), sanctions, and adverse media.
2. Supervise the resolution of Level 2 sanctions and screening alerts.
3. Review, validate, and track high-priority Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs).
4. Ensure timely and accurate preparation and submission of applicable STR/SAR filings to the Financial Reporting Centre (FRC) and CBK.
5. Regularly calibrate and test transaction-monitoring rules to enhance detection effectiveness.
6. Monitor emerging financial-crime typologies and recommend control enhancements.
7. Conduct Data Protection Impact Assessments (DPIAs) for new products, tools, systems, and processing activities.
8. Ensure adherence to the Data Protection Act, 2019, and coordinate requirements and filings with the Office of the Data Protection Commissioner (ODPC).
9. Maintain appropriate privacy governance and data-processing controls.
10. Establish governance controls for AI/ML models, focusing on fairness, transparency, accountability, and explainability.
11. Provide compliance oversight for automated decision-making and data-driven technologies.
12. Support the integration of privacy-by-design principles across new products and systems.
13. Establish and execute enterprise-wide KYC and KYB onboarding and periodic refresh procedures.
14. Ensure participant and merchant onboarding applications are verified and risk-scored within defined turnaround times.
15. Maintain scheduled periodic due diligence refresh cycles.
16. Ensure high-risk relationships undergo appropriate enhanced due diligence.
17. Verify Ultimate Beneficial Ownership (UBO), PEP involvement, corporate structures, licenses, and identification documentation.
18. Maintain an audit-ready centralized compliance repository.
19. Implement automated triggers for expiring licenses, identification documents, and risk-profile updates.
20. Conduct regular regulatory horizon-scanning activities.
21. Identify legislative and regulatory developments impacting payment operations.
22. Assess regulatory changes and coordinate the implementation of necessary control or policy adjustments.
23. Maintain a centralized repository of regulatory requirements, legal precedents, and relevant compliance opinions.
24. Support management with regulatory interpretation and compliance advisory services.
25. Support the operationalization and governance of the business Scheme Council.
26. Monitor interbank dispute-resolution Service Level Agreements (SLAs).
27. Prepare compliance and risk governance packs for Scheme Council meetings.
28. Conduct quality assurance reviews of interbank clearing and settlement message workflows.
29. Monitor participant compliance with applicable scheme requirements.
30. Establish and maintain compliance quality assurance processes across key operational activities.
31. Conduct periodic compliance reviews and control testing.
32. Identify control weaknesses and coordinate remediation efforts.
33. Maintain evidence and documentation required for internal, external, and regulatory reviews.
34. Track compliance issues through to closure.
35. Support legal and regulatory advisory activities relevant to business operations.
36. Maintain and develop a searchable Digital Legal Opinion Library.
37. Support the interpretation and implementation of applicable regulatory requirements.
38. Collaborate with Legal, Risk, Operations, Technology, and other functions to resolve compliance matters.
39. Maintain up-to-date knowledge of compliance functions and stay abreast of the latest practices, trends, and technologies.
40. Model best practices in compliance operations to ensure quality performance.
41. Update job knowledge through conferences, educational opportunities, professional publications, networking, and professional associations.
42. Maintain quality service and partnerships by establishing and enforcing company compliance policies, procedures, standards, and values.
43. Implement proper quality control checks and balances within each operational activity.
44. Regularly report on key performance indicators (KPIs) for all compliance-led projects and operations, demonstrating progress and identifying areas for improvement.

1. Hold a Bachelor’s Degree in Law, Compliance, Risk Management, Finance, Accounting, Business Administration, Information Systems, or a related discipline.
2. Possess professional qualifications in compliance, AML, risk, privacy, audit, or law (highly desirable).
3. Relevant certifications such as CAMS, ICA Compliance, CIPP/E, CIPM, CISA, CIA, CPA/ACCA, or equivalent are desirable, depending on the area of specialization.
4. Have at least 7 years of relevant work experience in compliance, AML/CFT, regulatory affairs, data protection, risk, financial crime, or related functions.
5. Possess at least 3 years of work experience in a managerial or senior supervisory position.
6. Experience within banking, payments, FinTech, financial services, or another regulated environment is highly desirable.
7. Demonstrate experience with AML transaction monitoring, KYC/KYB, regulatory compliance, and data protection.
8. Experience dealing with regulators, auditors, law enforcement, or industry scheme stakeholders is an advantage.
9. Possess strong AML/CFT/CPF compliance and financial-crime risk management experience.
10. Have experience with sanctions, PEP, adverse media, and transaction screening.
11. Demonstrate experience with STR/SAR review and regulatory reporting.
12. Possess experience conducting KYC/KYB and Enhanced Due Diligence (EDD).
13. Have strong UBO and corporate-structure analysis skills.
14. Possess data protection and privacy compliance skills, including DPIA preparation and privacy risk assessment.
15. Demonstrate regulatory interpretation, horizon-scanning, compliance monitoring, testing, and QA skills.
16. Have experience with AI/ML governance and responsible automated decision-making controls.
17. Possess a strong understanding of regulatory obligations affecting payment and financial services.
18. Be proficient with transaction-monitoring, KYC, screening, GRC, case management, and data analysis systems.
19. Demonstrate strong investigative and analytical skills.
20. Possess excellent report writing and documentation skills.
21. Have strong stakeholder management and communication skills.
22. Be able to exercise independent compliance judgment and escalate material issues.
23. Demonstrate strong attention to detail and ability to manage confidential information.
24. Be able to work effectively across cross-functional teams (compliance, legal, technology, operations, risk, and business).